Arbitration paperbooks: CD volumes, the Procedural Order, and the master index

A Statement of Claim for an arbitral tribunal is not assembled the way a High Court petition is, and treating the two alike is the commonest assembly mistake made at midnight. A court paperbook is one merged, bookmarked PDF. An arbitration paperbook is a set: the pleading, a master index, and the document volumes — each its own file, each built to whatever the tribunal's Procedural Order has fixed.

This page sets out the anatomy, so the set you send across is the set the tribunal expects.

One filing, several PDFs

For a claimant, the set is the Statement of Claim, the Master Index, and the Claimant's Documents volumes — CD-1, CD-2, CD-3 and onwards — with the annexures themselves numbered C-1, C-2, C-3 continuously across the whole set. A respondent mirrors it: RD- volumes, R- annexures, alongside the Statement of Defence.

The volumes stay separate. Tribunal members work volume by volume — one open on the desk, the rest within reach — and most Procedural Orders assume exactly that. Merging everything into one running PDF, however tidy it feels, produces the wrong deliverable for this forum.

What the Procedural Order fixes — and what it leaves open

The Procedural Order is the constitution of the filing. Read it before a single annexure is touched, because it usually speaks to:

• Pages per volume — 250 is a common ceiling; some references fix 200.
• Pagination — continuous, 1 to N across every volume, is the usual scheme; some tribunals direct numbering that restarts with each volume. Both exist in live references, so the PO decides, not habit.
• Per-volume indices — most references want each volume to open with its own index; a few dispense with it.
• Prefixes — CD-/C- for the claimant, RD-/R- for the respondent.

Just as important is what the PO is silent on. The master index alone has three homes in practice: a separate Master Index PDF, an index bound inside Volume 1, or one stitched in front of the Statement of Claim itself. Where the Order does not choose, that is a decision to be made — deliberately, and recorded — not a blank to be filled by whatever the last matter did.

CD volumes: how the documents get packed

There are two honest ways to split annexures into volumes. The first is mechanical: fill each volume to the page ceiling and start the next. The second is deliberate: group by theme, so the contract bundle sits together in one volume and the correspondence runs in another — the layout a tribunal actually finds easiest to work.

Two rules hold either way. A single exhibit is never split across volumes — a 300-page agreement travels whole. And pagination runs continuously across the set unless the PO says otherwise, so a citation to page 1,214 lands on page 1,214 no matter which volume it sits in.

The master index comes from the pleading, not the folder

The master index is not a listing of what the folder happens to contain. It is mined from the body of the pleading: every annexure the draft names, in the order the draft names it, under the exact title the draft gives it — then mapped to its volume and page span once the set is packed. Each annexure is bookmarked under that same pleaded title, and the whole set is searchable by default.

That is why the draft is the only organised thing the assembly needs. The folder can arrive as it sits.

How AIC builds the set

Send the drafted SOC or SOD, the Procedural Order, and the annexure folder in whatever state it is in. AIC reads the PO first and builds to it; wherever the Order is silent, AIC puts the open point to you in plain words and builds on your say-so — volume size, index placement, volume boundaries. Every file in the folder is matched to the annexure you pleaded, renamed to your exact title, and set in your sequence; while it matches, it verifies, and whatever doesn't sit against your draft comes back as one line on a check-sheet. We flag; we never edit.

Usually minutes — depending on how fast you get back to us — but it can take up to a few hours depending on the size of the filing. Files stay read-only, processed on our own machines, deleted on completion. The clerk, not counsel.

Questions litigators ask

My Procedural Order says nothing about volume size. What now?

Then it is your call, made once and applied throughout. 250 pages a volume is a widely used ceiling and a sensible default; AIC states the default, takes your instruction, and packs to exactly that.

Do you merge the volumes into one PDF?

No. An arbitration set is delivered as separate PDFs — the pleading, the master index, and each CD or RD volume on its own — because that is how tribunals direct it and how they read it. One merged PDF is a court deliverable, not an arbitration one.

I'm for the respondent. What changes?

Only the letters. RD- volumes, R- annexures, the same anatomy: master index from the body of the SOD, continuous pagination, per-volume indices as the PO directs.

Can you reproduce the volume layout of an earlier filing in the same reference?

Yes. Give the boundaries — which annexures make up which volume — and the set is packed to exactly those, with pagination and indices recalculated to the new record.