STATEMENT OF CLAIM
HKIAC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE HKIAC ADMINISTERED ARBITRATION RULES (2024)
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 16.1, to treat the Notice of Arbitration as the Statement of Claim:
The Claimant hereby elects to treat the Notice of Arbitration dated [date of the Notice of Arbitration] as its Statement of Claim, supplemented as set out below.
The Tribunal may, pursuant to Article 16.4, vary the content requirements set out below for this Statement of Claim.
Before filing, confirm that no Procedural Order has varied the document's required content.
Introduction
This Statement of Claim is submitted pursuant to Article 16 of the HKIAC Administered Arbitration Rules (2024).
The particulars required by Article 16.2 are: (a) a statement of the facts supporting the claim; (b) the points at issue; (c) the legal arguments supporting the claim; and (d) the relief or remedy sought.
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 pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration]. HKIAC's dedicated jurisdiction provision is Article 19.
This section is affirmative; the Claimant does not anticipate a jurisdictional objection. Should the Respondent contest jurisdiction, Article 19.3 requires that the objection be raised, if possible, in the Answer to the Notice of Arbitration, and no later than in the Statement of Defence (or, in respect of a counterclaim, in the Defence to the 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
The Claimant respectfully requests that the Tribunal: (a) DECLARE that [declaratory relief sought]; (b) ORDER the Respondent to pay [amount claimed], or such other sum as the Tribunal considers appropriate; (c) AWARD interest as pleaded above; (d) ORDER the Respondent to pay the costs of this arbitration; and (e) GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
Pursuant to Article 16.3, the Claimant shall annex to this Statement of Claim all supporting materials on which it relies.
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About this template
What is this template?
This is a formal legal filing used to initiate the substantive phase of an arbitration. It is not an initial Notice of Arbitration or an Answer to a claim. It specifically contains sections for a Dramatis Personae, a Contractual Matrix, and a table for Exhibit referencing as required by the HKIAC.
When should you use it?
Use this document after a Notice of Arbitration has been filed and the Tribunal requires a formal memorial of the case. Use the HKIAC Answer to Notice of Arbitration instead if you are the Respondent defending against a claim.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Invokes Article 16 of the HKIAC Administered Arbitration Rules (2024) to submit the formal claim. |
| 3 | Jurisdiction | Identifies the specific arbitration agreement clause and confirms the seat of arbitration as per Article 19. |
| 7 | Loss, Damage and Quantum | Requires the Claimant to particularise a specific amount claimed and define the interest rate for the award. |
| 8 | Relief Sought | Lists the five specific categories of relief requested, including declarations, payment orders, and arbitration costs. |
| 9 | Annexure Schedule | Obliges the Claimant under Article 16.3 to annex all supporting materials and exhibits relied upon in the narrative. |
Who it's for
- a claimant initiating formal proceedings under the 2024 HKIAC Administered Arbitration Rules
- legal representatives drafting a memorial for a case seated at a specific HKIAC arbitration center
- parties electing to treat a Notice of Arbitration as a Statement of Claim under Article 16.1
How long it runs and how it's signed
Law it's drafted under
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