SIAC Rules (2025, 7th Edition) — Statement of Defence
Archetype: Memorial
This document is prepared under the SIAC Rules (2025, 7th Edition), effective 1 January 2025. The Memorial archetype sets out full legal argument and evidence inline; contrast the Pleading archetype, which pleads material facts only.
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 Matters
Include the following paragraph only if the Respondent elects, pursuant to Rule 7.2 of the SIAC Rules (2025, 7th Edition), to include its Statement of Defence (and Statement of Counterclaim, if any) in its Response to the Notice of Arbitration:
The Respondent elects to include its Statement of Defence in its Response to the Notice of Arbitration. This election is optional for the Respondent under Rule 7.2, in contrast to the Claimant's position under Rule 6.4, where the equivalent election is mandatory if made.
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable with the Registrar or Tribunal before filing this Statement of Defence.
Jurisdiction Gate — Time-Bar Warning. Any jurisdictional objection is governed by Rule 31.2(a) of the SIAC Rules (2025, 7th Edition), which is dual-limbed: an objection that the Tribunal does not have jurisdiction must be raised no later than in a Statement of Defence or, with respect to a counterclaim, in a Statement of Defence to a Counterclaim. Confirm which limb applies to this Respondent's position before filing. A party may also flag an objection earlier, in the Response, per Rule 7.1(d) — this is optional and does not itself set the time-bar.
STATEMENT OF DEFENCE
Where a counterclaim is pleaded within this document (see Section 13 below), the title should read "STATEMENT OF DEFENCE AND 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")
— and —
[Respondent's name] of [Respondent's address] ("Respondent")
Submitted on behalf of the Respondent by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Defence is submitted pursuant to Rule 33.3, in reply to the particulars of the Statement of Claim.
Section index: (I) Third-Party Funding Disclosure; (II) the Parties; (III) Jurisdiction; (IV) General Traverse; (V) Paragraph-by-Paragraph Reply; (VI) Factual Background; (VII) Legal Grounds; (VIII) Affirmative Defences; (IX) Quantum Response; (X) Statement of Counterclaim, if pleaded; (XI) Relief Sought; (XII) Annexure Schedule.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses that no third-party funding agreement exists as at the date of this Statement of Defence.
Where a third-party funding agreement exists, substitute the following for paragraph 3: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
The Parties
Paragraphs [ ] of the 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]. This objection is raised within the deadline set out in Section 1 above.
General Traverse
Save as expressly admitted in this Statement of Defence, the Respondent denies each and every allegation made in the Statement of Claim as if set out here and traversed individually.
Paragraph-by-Paragraph Reply
Use "Not Admitted" for allegations outside the Respondent's own knowledge, rather than a positive denial.
SoC ¶ | 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 if the Respondent pleads set-off:
Set-Off. The Respondent pleads set-off in the amount of [amount] against any sum found due to the Claimant. This is pleaded as a defence pursuant to Rule 33.3(b), and is distinct from any counterclaim pleaded in Section 13 below — set-off pleaded as a defence does not attract counterclaim fees.
Quantum Response
The Respondent's position on the Claimant's pleaded quantum of [amount]: [admit / dispute in whole or part, with reasons].
Statement of Counterclaim
Include the following section only if the Respondent pleads a counterclaim. Note that the SIAC Rules (2025, 7th Edition) have no free-standing "Statement of Counterclaim" article: Rule 33.3 requires the Respondent to deliver "a Statement of Defence (and Statement of Counterclaim, if any)" setting out, among other things, a statement of facts supporting the defence and the counterclaim, and the legal grounds or arguments supporting the defence, counterclaim, cross-claim, or set-off. Because a counterclaim is itself a claim, this section reuses the full Statement of Claim element set.
Facts supporting the counterclaim. [Insert.]
Legal grounds. [Insert.]
Relief and quantum sought on the counterclaim. [amount].
Relief Sought
The Respondent respectfully requests that the Tribunal: (a) DISMISS the Statement of Claim in its entirety, alternatively in part; (b) AWARD the Respondent [amount] on the Counterclaim; (c) ORDER the Claimant to pay the costs of this arbitration; and (d) GRANT such further or other relief as the Tribunal considers just.
Delete limb (b) if no counterclaim is pleaded, and re-letter accordingly.
Annexure Schedule
Pursuant to Rule 33.7 of the SIAC Rules (2025, 7th Edition), this Statement of Defence 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.
Exhibit No. | Description | Referenced at ¶ |
Signature Block
Respectfully submitted,
[Representative's title] [Representative's name]
On behalf of the Respondent Date: [Date]
Seat Overlay
SIAC being the administering institution does not mean the seat of arbitration is Singapore — confirm the seat under the arbitration agreement and insert the applicable seat-law overlay accordingly.
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