You do the usual court header, with Skeleton Argument of the Applicant (or Respondent depending which you are)
And then you do subheadings which are:
Background -
this only has to be a paragraph or two, and should be the ages of the parties,the ages of the children, the length of the marriage etc.
Applicable Law -
this is Section 25 Matrimonial Causes Act 1973 (as amended) and a list of any case law you are using;
The Argument -
This is the main body, and which is where you set out what you think should happen and why. In mine, I quite often insert section 25 MCA and give a paragraph on each subsection as to how that has an effect. You can download the section 25 criteria here:
Summary -
This is where you summarise your case, and the final paragrah should be along the lines of:
Accordingly the Applicant (or Respondent, if that is you) seeks the following order:
And then set out the order, in money terms, that you seek, i.e.
A lump sum of £50,000 to the Applicant;
Transfer of the matrimonial home to the Applicant;
A 50% pension sharing order of the XYZ pension numbered 123;
Transfer of the ABC policy numbered 124 to the Respondent
etc etc.
Tips on writing a skeleton argument for final hearing (ancillary relief)
