Affidavit of Tomas Okonkwo, car park collision

Affidavit template with numbered paragraphs, exhibits and a jurat

An affidavit is sworn evidence, so it has to identify the case, say who is giving the evidence, set out what they saw in numbered paragraphs, and end with a jurat signed in front of an authorised person. This two page example is an independent witness to a car park collision, with three photographs and documents marked as exhibits.

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Claim MC 2026/04417, affidavit of T. OkonkwoPage 1 of 2
Claim MC 2026/04417, affidavit of T. OkonkwoPage 2 of 2
Filed for
Claimant
Deponent
T. Okonkwo, first affidavit
Exhibits
TO1 to TO3
Sworn
Thursday 8 October 2026
In the Magistrates Court, Civil Division. Claim number MC 2026/04417

Ruth Abernathy, Claimant, and Torvane Freight Ltd, Defendant

Affidavit of Tomas Okonkwo

I, Tomas Okonkwo, of 19 Bellfield Road, Halden, pharmacist, make oath and say as follows.

1.
I am not a party to this claim and I do not know either party. I make this affidavit as an independent witness to a collision in the car park of Gannetvale Shopping Centre on Saturday 12 September 2026.
2.
Everything in this affidavit is from my own knowledge, except paragraph 11, which is information I was given. I say where it came from.
3.
At about 10:40 am I was sitting in my car in bay C14, facing the loading dock, with the engine off. The weather was dry and sunny.
4.
I saw a silver hatchback stopped in the aisle in front of me, waiting behind a pedestrian with a pram. Its brake lights were on.
5.
A white delivery van with Torvane Freight signage was reversing out of the loading dock on the left of the aisle. I did not hear a reversing alarm and I did not see anyone guiding it.
6.
The van reversed into the driver side rear door of the hatchback. The hatchback did not move before the impact.
7.
The van stopped about two metres further on. The driver got out and said to the woman in the hatchback, "I didn't see you, you were in my blind spot."
8.
Between 10:43 am and 10:46 am I took four photographs on my phone showing both vehicles where they stopped. There is now shown to me marked TO1 a true copy of those photographs.
9.
There is now shown to me marked TO2 a sketch of the aisle and both vehicles, which I drew at home that afternoon while it was fresh in my mind.
10.
I gave the woman, who I now know is the claimant, my name and number. There is now shown to me marked TO3 a copy of the email I sent her at 2:15 pm the same day, attaching the photographs.
11.
A centre security officer told me at about 10:55 am that the dock camera covers that aisle. I have not seen the footage, but I believe what he told me.
12.
I have read this affidavit and it is true.
Exhibits
Mark
Description
Pages
TO1
Four photographs, 10:43 am to 10:46 am, 12 September 2026
Four
TO2
Sketch of the aisle and both vehicles
One
TO3
Email to the claimant, 2:15 pm, 12 September 2026
One
Jurat

Sworn by the deponent at 4 Court Lane, Halden on Thursday 8 October 2026, before me. Each exhibit was shown to the deponent and marked by me at the time of swearing.

Deponent
Name
:
Tomas Okonkwo
Date
:
Before me
Name
:
Imogen Hartley
Qualification
:
Solicitor
Address
:
4 Court Lane, Halden
Date
:

Section by section

What each section is for, so you can keep the ones you need and drop the rest.

Filing details
Who it is filed for, the deponent and affidavit number, the exhibit marks and the date sworn.
Court and parties
The court, claim number MC 2026/04417, and the claimant and defendant.
Title and opening
Affidavit of Tomas Okonkwo, with his address and occupation.
Numbered paragraphs 1 to 12
Independence, source of knowledge, the collision in time order, the exhibits and the hearsay paragraph.
Exhibits table
TO1 to TO3 with descriptions and page counts.
Jurat
Where and when it was sworn, with exhibits marked at swearing.
Signatures
The deponent, and the solicitor before whom it was sworn.

How to adapt this document

First, change the heading to your court's exact name and the claim number on your papers, and put the filing details where your court's rules ask for them, often the top right corner of the first page. Second, if you are a party rather than an independent witness, replace paragraph 1 with your role in the case and keep the rest in the same time ordered style. Third, if you have many documents, give each its own mark and keep the marks running across all your affidavits in the case, rather than restarting at 1 each time.

Format rules vary by court

The layout here follows the common law pattern set out, for example, in the Practice Direction to Part 32 of the Civil Procedure Rules for England and Wales: first person, numbered paragraphs, sources of information and belief stated, exhibits introduced with the standard words, and a jurat completed by an independent person whose name and qualification are printed. Courts in Australia, Canada, New Zealand and elsewhere use close variants, with their own forms for the heading and jurat. Before filing, compare this layout against the form your court publishes.

What makes this document work

Own knowledge and hearsay are kept apart

Paragraph 2 says everything is from the deponent's own knowledge except paragraph 11, and paragraph 11 names its source: a security officer at about 10:55 am who said the dock camera covers the aisle. Courts give different weight to what a witness saw and what they were told, so the affidavit says which is which.

Exhibits are introduced in the standard words

Paragraphs 8 to 10 each use the phrase there is now shown to me marked, then a mark: TO1 for four photographs taken from 10:43 am, TO2 for a sketch drawn that afternoon, TO3 for an email at 2:15 pm. The exhibits table repeats the marks with page counts, so nothing can be swapped later.

The jurat identifies the person who took the oath

The jurat states where and when the affidavit was sworn and that each exhibit was shown and marked, and the second signature block prints the solicitor's name, qualification and address. An affidavit whose witness cannot be identified, or which is signed by someone acting for a party, can be rejected.

Questions people ask

What is the difference between an affidavit and a statutory declaration?

An affidavit is evidence for a court case, so it carries the court heading and claim number and is sworn or affirmed. A statutory declaration is a written statement for other purposes, such as an insurer or agency, made under a declarations Act. Both are offences to make falsely, but they are not interchangeable.

Can I affirm instead of swearing an affidavit?

Yes. An affirmation has the same legal effect as an oath and suits anyone who prefers not to swear on a religious text. The jurat then reads affirmed rather than sworn. Tell the person taking it which you want before you start, so the wording on the document matches what you say.

Who can take an affidavit?

It depends on the court and the country, but it is usually a lawyer, a Justice of the Peace, a commissioner for oaths or a court officer. The person must be independent of the parties, which is why a solicitor from another firm takes this one. Check the rules of the court the affidavit is for.

Should an affidavit be written in the deponent's own words?

Yes, as far as practicable, and in the first person. A lawyer can help with structure, but phrases the witness would never use invite challenge in cross examination. This affidavit keeps plain language, such as the driver's words quoted exactly in paragraph 7, so the witness can stand behind every sentence.

What if I make a mistake after the affidavit is sworn?

Do not change the sworn document. Swear a second affidavit that corrects the error and explains it, numbered as the deponent's second affidavit, with any new exhibits continuing the existing marks. Alterations made before swearing must be initialled by both the deponent and the person taking the affidavit.

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Sources

Written and checked by the OneCraft team. Last checked .