LCIA Statement of Reply (Pleading)
The Claimant's reply to the Statement of Defence under Art. 15.4, due 28 days from receipt of the Statement of Defence (or the Respondent's election under Art. 15.3(i)). This is the pleading form — bare material facts addressing new matters raised in the Defence, and, where the Respondent raised a Counterclaim, a bare-facts Defence to Counterclaim only. Use where the Tribunal directs a facts-first approach or counsel prefers to defer legal argument.
STATEMENT OF REPLY [AND DEFENCE TO COUNTERCLAIM]
["AND DEFENCE TO COUNTERCLAIM" appears in the title, and Sections 3–6 below apply, only where the Respondent has raised a Counterclaim in its Statement of Defence and this filing also serves as the Claimant's Defence to Counterclaim, pursuant to Art. 15.4.]
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"["Counterclaim-Respondent"])
— and —
[Respondent's name]
[Respondent's address]
("Respondent" ["Counterclaim-Claimant"])
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
Introduction
This Statement of Reply is submitted pursuant to Art. 15.4 of the LCIA Arbitration Rules (2020), pleading material facts only in response to new matters raised in the Statement of Defence[, and in defence of the Counterclaim], within 28 days of the Claimant's receipt of the Respondent's Statement of Defence[/Counterclaim] or of the Respondent's election under Art. 15.3(i).
Reply to the Statement of Defence
(Material Facts Only)
[Bare facts addressing new matters raised in the Statement of Defence — no argument.]
Defence to Counterclaim —
General Traverse[Include Sections 3–6 only where this filing also serves as the Defence to Counterclaim.]
Save as expressly admitted below, the Claimant/Counterclaim-Respondent denies each allegation in the Counterclaim.
Defence to Counterclaim — Paragraph-by-Paragraph Reply
Counterclaim ¶ | Allegation (summary) | Response |
Defence to Counterclaim — Material Facts and Bare Defences
[Bare facts only, no argument.]
Affirmative Defence 1 (bare): [basis, if applicable].
[Include the following paragraph only where the Claimant/Counterclaim-Respondent pleads a set-off against the Counterclaim: "Set-Off. Pleaded in the amount of [set-off amount] — bare characterisation only. The LCIA Rules do not provide a distinct set-off mechanism; not the same as LCIA's 'cross-claim' concept (inter-respondent claims only, Art. 2.1(iii))."]
Quantum Response on the Counterclaim
Position on [counterclaim quantum amount]: [admit / dispute].
Relief Sought
The Claimant seeks:
the relief sought in the Statement of Case;
[where a Counterclaim is pleaded] dismissal of the Counterclaim;
[where a set-off is pleaded against the Counterclaim] effect given to the set-off of [set-off amount];
[where a Counterclaim is pleaded] costs of the Counterclaim;
costs of this arbitration; and
further or other relief.
Reservations
The Claimant reserves the right to amend or supplement this Statement of Reply at the appropriate stage of the proceedings.
Annexure Schedule
All documents relied upon by the Claimant accompany this Statement of Reply, in accordance with Art. 15.4, as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant[/Counterclaim-Respondent]
Date: [date]
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