SIAC Statement of Defence to Counterclaim (Pleading)
SIAC Rules (2025, 7th Edition) — Statement of Defence to Counterclaim
This is the Claimant/Counterclaim-Respondent's reply to the Respondent's Statement of Counterclaim, submitted under Rule 33.4, pleading bare material facts and traverse only, with no argument.
Preliminary Matters
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable.
Jurisdiction Gate — Counterclaim. Per Rule 31.2(a) of the SIAC Rules (2025, 7th Edition) — the second limb — any objection to jurisdiction over the Counterclaim must be raised in this document if not already raised. See Section 4 below.
STATEMENT OF DEFENCE TO 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]
[Claimant's address]
("Claimant," "Counterclaim-Respondent")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Claimant/Counterclaim-Respondent by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Defence to Counterclaim is submitted pursuant to Rule 33.4, pleading material facts only. Section index: (I) Third-Party Funding Disclosure; (II) Jurisdiction (Counterclaim); (III) General Traverse; (IV) Paragraph-by-Paragraph Reply; (V) Rule 33.4(a) — Material Facts; (VI) Rule 33.4(b) — Cross-Claim/Set-Off (bare characterisation only); (VII) Rule 33.4(c) — Relief Sought.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Claimant/Counterclaim-Respondent discloses [state one: the existence of a third-party funding agreement, together with the identity and contact details of the funder; OR that no third-party funding agreement exists].
Jurisdiction (Counterclaim)
[State one: Objection to jurisdiction over the Counterclaim on the following bare basis: [state basis — no argument]; OR No objection is raised to jurisdiction over the Counterclaim.]
General Traverse
Save as expressly admitted below, the Claimant/Counterclaim-Respondent denies each allegation in the Statement of Counterclaim.
Paragraph-by-Paragraph Reply
Drafting note: use "Not Admitted" for allegations outside the Claimant/Counterclaim-Respondent's own knowledge, rather than a positive denial.
Material Facts
[Bare facts only, no argument.]
Rule 33.4(a) —
7. Cross-Claim / Set-Off (Bare Characterisation)
[Include the following paragraph only if the Claimant/Counterclaim-Respondent pleads set-off or a cross-claim within this document:]
Set-Off / Cross-Claim. Pleaded in the amount of [amount] — bare characterisation only, per Rule 33.4(b). This is a separate set-off from any pleaded by the Respondent in its own Statement of Defence.
Rule 33.4(b)
8. Relief Sought
The Claimant/Counterclaim-Respondent seeks: (a) dismissal of the Statement of Counterclaim; [Include the following only if set-off/cross-claim is pleaded: (b) effect given to the set-off/cross-claim of [amount];] (c) costs of the Counterclaim; and (d) further or other relief.
Rule 33.4(c)
9.Reservations
The Claimant/Counterclaim-Respondent reserves the right to amend or supplement this document 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.
Signature Block
Respectfully submitted,
[Representative's title] [Representative's name]
On behalf of the Claimant/Counterclaim-Respondent
Date: [Date]
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