Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF CLAIM
DIAC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE DIAC ARBITRATION RULES 2022
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
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 Claimant elects, pursuant to Article 4.2, to include the Statement of Claim referred to in Article 24.1 as part of its Request:
The Claimant hereby elects to include, as part of its Request dated [date of the Request], the detailed statement of claim referred to in Article 24.1, so that the Request itself stands as the Statement of Claim, supplemented as set out below.
If the Statement of Claim is not filed with the Request, Article 24.1 requires the Claimant to submit it within such time as the Tribunal determines after consultation with the parties (including at the preliminary meeting under Article 23.3); there is no fixed default period.
Introduction
This Statement of Claim is submitted pursuant to Article 24.1 of the DIAC Arbitration Rules 2022 (the "Rules"), administered by the Dubai International Arbitration Centre ("DIAC").
Defined terms used in this Statement of Claim have the meanings given to them in the Request dated [date of the Request], unless otherwise defined herein.
Section index: (I) the Parties; (II) Jurisdiction; (III) Factual Background; (IV) Legal Grounds; (V) Loss and Quantum; (VI) Relief Sought; (VII) Annexure Schedule.
The Parties
The Claimant is [Claimant's name], [description].
The Respondent is [Respondent's name], [description].
Jurisdiction
The Tribunal has jurisdiction over this dispute pursuant to the agreement to arbitrate at [clause reference] of [contract name], seated at [seat of arbitration]. Pursuant to Article 6.1, the Tribunal has the power to rule on its own jurisdiction, and the agreement to arbitrate is treated as separable from the underlying contract.
This section is affirmative; the Claimant does not anticipate a jurisdictional objection. Should the Respondent contest jurisdiction, Article 6.4 requires that the objection be raised no later than in the statement of defence or, as the case may be, in any statement of defence to counterclaim.
Factual Background
Chronology. [Insert.]
Dramatis Personae. [Insert.]
Contractual Matrix. [Insert.]
Narrative. [Insert, cross-referenced to exhibits.]
Legal Grounds
Cause of Action 1. [State the legal basis, with authorities.]
Cause of Action 2. [If applicable.]
Loss, Damage and Quantum
The Claimant has suffered loss and damage in the amount of [amount claimed], particularised as follows: [quantum breakdown].
Interest is claimed at [interest rate] from [date from which interest is claimed].
Relief Sought
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About this template
What is this template?
This is a formal legal filing for use in international arbitration, specifically designed to comply with the 2022 DIAC Rules. It is not a contract or an agreement, but a submission that sets out the claimant's entire case, including quantum breakdowns and legal authorities. It contains specific sections for the Dramatis Personae and a structured Annexure Schedule for exhibits.
When should you use it?
Use this template when an arbitration tribunal has directed the submission of a Memorial or when filing a Request for Arbitration that includes the Statement of Claim. Use a Request for Arbitration instead if the proceedings have not yet been formally initiated.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Identifies that the submission is made pursuant to Article 24.1 of the DIAC Arbitration Rules 2022. |
| 3 | Jurisdiction | Specifies the agreement to arbitrate, the seat of arbitration, and references the Tribunal's power to rule on jurisdiction under Article 6.1. |
| 4 | Factual Background | Organises the claim's narrative through a chronology, a list of dramatis personae, and a description of the contractual matrix. |
| 6 | Loss, Damage and Quantum | Requires the Claimant to particularise the total amount claimed and specify the interest rate and calculation date. |
| 7 | Relief Sought | Lists the specific declarations and orders requested from the Tribunal, including declaratory relief, payment of sums, and arbitration costs. |
| 8 | Annexure Schedule | Provides a structured table for indexing evidence and exhibits as required by Article 24.1. |
Who it's for
- a party seeking to formalise its legal arguments in a Dubai International Arbitration Centre proceeding
- a claimant electing to include a detailed statement of claim as part of their Request under Article 4.2
- a legal representative drafting a memorial following a preliminary meeting under Article 23.3
How long it runs and how it's signed
How long
Used once
Signed by
Claimant's Representative
Witness
Not required
Notarisation
Not required
Also needed
File with Dubai International Arbitration Centre
Law it's drafted under
Governed by
DIAC Arbitration Rules 2022
Required by
Article 24.1 DIAC Rules
Refers to
Article 6.1 DIAC Rules
Jurisdiction
United Arab Emirates
Dubai (United Arab Emirates)
General
Document info
GitLaw document. Document created on Mon Aug 10th, 2026. Last updated on Mon Aug 10th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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