Answer and Statement of Defence (HEAP Track, Memorial) (ICC Rules) by OLL
ANSWER AND STATEMENT OF DEFENCE [AND STATEMENT OF COUNTERCLAIM]
ICC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026) (HIGHLY EXPEDITED ARBITRATION — APPENDIX VI)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Respondent by: [Representative's title and name]
Date: [date]
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Preliminary Notes
"HEAP" is ICC's own shorthand for the Highly Expedited Arbitration Provisions (Appendix VI), also referred to as "Highly Expedited Arbitration" in Article 33 of the main Rules. Under HEAP, the Tribunal is a sole arbitrator, the award is due within 3 months of the initial CMC, document production may be refused entirely, and the case may be decided on documents alone.
Merged Filing. This single document constitutes both the Answer to the Request for Arbitration and the Statement of Defence — and, if any, the Statement of Counterclaim — filed together pursuant to Appendix VI, Article 2(5): "the respondent shall submit its Answer, which shall contain the following information, as well as its statement of defence ('Answer and Statement of Defence') and statement of counterclaim, if any ('Statement of Counterclaim')." Because Appendix VI requires the full legal and factual basis — and, to the extent possible, the evidence relied on — to be filed with the Answer, this document is necessarily drafted in full-argument form; there is no abbreviated facts-only variant under HEAP.
Counterclaims. Appendix VI, Article 2(5)-(8) gives HEAP its own counterclaim mechanism, distinct from but parallel to the Standard track's Article 6(4)-(5) — see Section 10 below.
Jurisdiction. Article 7 ("Effect of the Arbitration Agreement") gives the Tribunal authority to decide jurisdiction questions but fixes no filing deadline for raising the plea. This applies equally under HEAP; nothing in Appendix VI overrides Article 7 on this point.
Confirm the Parties have opted into Highly Expedited Arbitration pursuant to Appendix VI/Article 33 before using this template — HEAP is never the default track.
Introduction
This Answer and Statement of Defence is submitted together, pursuant to Appendix VI/Article 33, given the Parties' opt-in to HEAP.
Includes the full legal and factual basis and, to the extent possible, the evidence relied on in response.
Section index: (I) the Parties; (II) Jurisdiction; (III) General Traverse; (IV) Paragraph-by-Paragraph Reply; (V) Factual Background; (VI) Legal Grounds; (VII) Affirmative Defences; (VIII) Statement of Counterclaim, if any; (IX) Quantum Response; (X) Evidence Relied On; (XI) Relief Sought.
The Parties
Paragraphs [ ] of the Request/Statement of Claim as to the identity of the Parties are ADMITTED, save as pleaded below.
Jurisdiction
The Respondent does not object to the Tribunal's jurisdiction.
Where the Respondent objects to jurisdiction, substitute the following for paragraph 5: The Respondent objects to the Tribunal's jurisdiction on the following factual and legal basis: [state basis].
General Traverse
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