SIAC Rules (2025, 7th Edition) — Statement of Counterclaim
Archetype: Pleading
This standalone document is for use where the counterclaim is filed as its own document rather than merged into the Statement of Defence, pleading material facts only. The SIAC Rules (2025, 7th Edition) have no free-standing "Statement of Counterclaim" article; the citation basis is Rule 33.3, the Statement of Defence provision, which expressly extends to the counterclaim.
STATEMENT OF COUNTERCLAIM
SIAC Case No.: [Insert case number, if assigned]
IN THE MATTER OF AN ARBITRATION UNDER THE SIAC RULES (2025, 7th EDITION)
BETWEEN
[Claimant's name] of
[Claimant's address]
("Claimant," "Counterclaim-Respondent")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Respondent/Counterclaim-Claimant by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Counterclaim pleads material facts only. Set-off, if pleaded, is addressed only in the Statement of Defence and is not part of this document.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Counterclaim-Claimant discloses that no third-party funding agreement exists.
Where a third-party funding agreement exists, substitute the following for paragraph 2: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Counterclaim-Claimant discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
The Parties
[Cross-reference the Statement of Defence rather than repeat.]
Jurisdiction
Jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence.
Material Facts
[Bare facts supporting the counterclaim — no argument.]
Breach Alleged
[Bare characterisation of the counterclaim's cause of action.]
Loss and Damage
Loss and damage of [amount] [quantified].
Interest claimed at [interest rate] from [date].
Relief Sought
The Respondent/Counterclaim-Claimant seeks: (a) [amount]; (b) interest as pleaded; (c) costs of the Counterclaim; and (d) further or other relief.
Reservations
The Respondent/Counterclaim-Claimant reserves the right to amend or supplement this Statement of Counterclaim pursuant to Rule 33.5.
Annexure Schedule
Pursuant to Rule 33.7 of the SIAC Rules (2025, 7th Edition), this submission shall be accompanied by copies of all supporting documents that have not previously been submitted by any party. The Tribunal may, after considering the views of the parties, further direct that this submission be accompanied by supporting witness statements and expert reports.
Respectfully submitted,
[Representative's title] [Representative's name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [Date]
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