STATEMENT OF DEFENCE [AND COUNTERCLAIM]
["AND COUNTERCLAIM" appears in the title only where the Respondent raises a Counterclaim in this filing.]
LCIA Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE LCIA ARBITRATION RULES (2020)
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]
Introduction
This Statement of Defence is submitted pursuant to Art. 15.3 of the LCIA Arbitration Rules (2020), in reply to the Statement of Case, within 28 days of the Respondent's receipt of the Statement of Case or of the Claimant's election under Art. 15.2.
This Statement of Defence is organised as follows: (I) the Parties; (II) Jurisdiction; (III) General Traverse; (IV) Paragraph-by-Paragraph Reply; (V) Factual Background; (VI) Legal Grounds; (VII) Affirmative Defences; (VIII) Quantum Response; (IX) Counterclaim, where applicable; (X) Relief Sought.
The Parties
Paragraphs [ ] of the Statement of Case 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 the Tribunal's jurisdiction, substitute for this paragraph: "The Respondent objects to the Tribunal's jurisdiction on the following factual and legal basis: [state basis]. This objection is raised no later than the time for this Statement of Defence, in accordance with Art. 23.3 of the LCIA Rules."]
General Traverse
Save as expressly admitted in this Statement of Defence, the Respondent denies each and every allegation made in the Statement of Case as if set out here and traversed individually.
Paragraph-by-Paragraph Reply
Statement of Case ¶ | Allegation (summary) | Response |
Factual Background
Respondent's factual narrative, cross-referenced to exhibits.
Legal Grounds
Respondent's legal argument in answer to each cause of action.
Affirmative Defences
Affirmative Defence 1: [basis].
Affirmative Defence 2: [if applicable].
Include the following paragraph only where the Respondent pleads a set-off: "Set-Off. The Respondent pleads set-off in the amount of [set-off amount] against any sum found due to the Claimant. The LCIA Rules do not provide a distinct set-off mechanism; this set-off is accordingly pleaded as an ordinary affirmative defence. ("Cross-claim" under the Rules refers instead to a claim by one respondent against another respondent in multi-party proceedings — see e.g. Art. 2.1(iii), 22.1(i)/(viii) — and is a separate concept from a set-off defence.) Where the amount of the set-off exceeds the Claimant's claim, it is pleaded instead as a Counterclaim under Art. 15.3 (see Section 9 below)."
Quantum Response
The Respondent's position on the Claimant's pleaded quantum of [quantum amount]: [admit / dispute in whole or part, with reasons].
Counterclaim
Include this Section only where the Respondent raises a Counterclaim in this Statement of Defence, pursuant to Art. 15.3(ii).
Facts supporting the counterclaim. [Insert.]
Legal grounds. [Insert, with authorities.]
Relief and quantum sought on the counterclaim. [counterclaim quantum amount].
Relief Sought
The Respondent respectfully requests that the Tribunal:
DISMISS the Statement of Case in its entirety, alternatively in part;
[where a Counterclaim is pleaded] AWARD the Respondent [counterclaim quantum amount] on the Counterclaim;
ORDER the Claimant to pay the costs of this arbitration; and
GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
All documents relied upon by the Respondent (including, where applicable, in support of the Counterclaim) accompany this Statement of Defence, in accordance with Art. 15.3(ii), as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent
Date: [date]
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