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This issue can become particularly fraught by the time of an appeal. Initially there was a witness statement meticulously cross-referenced to a paginated exhibit. That exhibit or its component documents (which arguably should be arranged consecutively rather than within their exhibits) then ends up in a continuously paginated trial bundle to which the resulting judgment then refers. On appeal only documents relevant to the appeal should go in the appeal bundle (it must not be the whole trial bundle all over again) which is again consecutively paginated. So the same document has had at least 3 different page numbers by this point.
Counsel’s skeleton argument will inevitably refer to the relvant page in the relevant hearing bundle which supports the point being made. But of the judge wants to read the witness statement as originally drafted with its accompanying exhibit then those documents are now scattered far and wide with multiple page numbers thereon.
There are only so many places a page number can be put and the significance of each one of many is not automatically obvious. Repeated annotation in manuscript of the witness statement to track the latest whereabouts of the relevant intended document is messy – shouls superseded annotations be scratched out? Ir a sequence of colours as used to be thr case with amendments to pleadings?
I have read strong judicial criticism of (and indeed costs arguments based upon) non-consecutive pagination in favour of numbered dividers, with each individual starement of case or document etc. having its own pagination that it had when drafted in Word. Others judges are fine with it, presumably on the basis that divider 5, page 21 is arguably quicker to find than just page 299. Surely quicker is better, given the previousness of court time.
It is unfortunate if preparation of acceptable bundles is reduced to mind games about how the judge might want to read their contents, either as guided by counsel or left to their own devices.