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Cut a length of 2 x 1 to the radius, drill a hole in the end of the 2x1, knock in a 'pin' at the centre of the radius, through the hole in the 2x1. You now have a trammel. Each post can be 'uprighted' against the trammel and height adjusted by bedding them on 50mm or so of damp concrete, that way you can concrete both sides, which you must do for stability. We also angle tacked the tops together as we go with a small sheradised pin, which keeps it all standing nicely until you CAREFULLY top up with concrete. I think we use a 1/3 in the ground and 2/3 out.
Thanks Colin - not sure that the trammel can work though,it's an existing bed that we're extending so the trammel will be obstructed by shrubs.
If you can't get the batten through the shrubs, but are happy with the shape you have dug, then I would think that the only alternative is to butt against the back of the trench, then retro dig out behind the poles.