Statement of Claim (Memorial) (UNCITRAL Rules) by OLL
This formal legal pleading sets out a claimant's full case, including factual background and legal arguments, under the UNCITRAL Arbitration Rules (2021). It provides a structured framework for detailing the dispute's history, the tribunal's jurisdiction, and specific relief sought by the initiating party.
This document comes from OLL's library of vetted legal templates.
UNCITRAL Arbitration Rules (2021) — Memorial Archetype
This archetype sets out the Claimant's full case, including legal argument and evidence, together with the facts. For a facts-only pleading that defers argument and evidence to a later stage, see the Pleading archetype of this template.
STATEMENT OF CLAIM
[Case No.: [Case number, if allocated]]
IN THE MATTER OF AN ARBITRATION UNDER THE UNCITRAL ARBITRATION RULES (2021)
BETWEEN
[Claimant's name] of
[Claimant's address]
("Claimant")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent")
Submitted on behalf of the Claimant by: [Representative's title, e.g. Counsel for the Claimant] [Name of representative]
Date: [Date of this Statement of Claim]
Introduction
Include the following Election Notice only if the Claimant elects, pursuant to Art. 20(1) of the UNCITRAL Arbitration Rules (2021), to treat its Notice of Arbitration as its Statement of Claim: "Pursuant to Art. 20(1) of the UNCITRAL Arbitration Rules (2021), the Claimant hereby elects to treat its Notice of Arbitration dated [date] as its Statement of Claim, supplemented as set out below."
This Statement of Claim is submitted pursuant to Art. 20 of the UNCITRAL Arbitration Rules (2021).
Defined terms used in this Statement of Claim have the meanings given to them in the Notice of Arbitration dated [date of Notice of Arbitration], unless otherwise defined herein.
This Statement of Claim is structured as follows: (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 of Claimant].
The Respondent is [Respondent's name], [description of Respondent].
Jurisdiction
The Tribunal has jurisdiction over this dispute pursuant to the arbitration agreement at [clause reference] of [contract name], which provides for arbitration under the UNCITRAL Arbitration Rules seated at [seat of arbitration].
The Claimant is not aware of any basis on which the Tribunal's jurisdiction is contested. If the Respondent raises a jurisdictional objection, Art. 23(2) requires that it be raised no later than the Statement of Defence.
Factual Background
Chronology. [Insert chronological table of key events.]
Dramatis Personae. [Insert list of individuals/entities relevant to the narrative.]
Contractual Matrix. [Insert description of the relevant agreement(s) between the Parties.]
Narrative. [Insert full factual narrative supporting the claim, cross-referenced to exhibits, per Art. 20(2).]
Legal Grounds
Cause of Action 1. [State the legal basis, with authorities.]
Cause of Action 2. [State the legal basis, with authorities, if applicable.]
Loss, Damage and Quantum
As a result of the matters set out above, the Claimant has suffered loss and damage in the amount of [quantum amount], particularised as follows: [insert quantum breakdown].
The Claimant claims interest on the above sum at the rate of [interest rate] from [interest start date] to the date of payment.
Relief Sought
The Claimant respectfully requests that the Tribunal: (a) DECLARE that [declaratory relief sought]; (b) ORDER the Respondent to pay the Claimant the sum of [quantum amount], or such other sum as the Tribunal considers appropriate; (c) AWARD interest as set out in paragraph 15 above; (d) ORDER the Respondent to pay the costs of this arbitration, including the Claimant's legal and other costs; and (e) GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
Pursuant to Art. 20(3), a copy of the contract or other legal instrument out of which the dispute arises, and of the arbitration agreement itself, shall be annexed to this Statement of Claim. In addition, pursuant to Art. 20(4), all other documents and evidence relied upon by the Claimant should, as far as possible, be annexed hereto or referenced below.
Exhibit No. | Description | Referenced at ¶ |
[Document] | ¶ [ ] | |
[Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title]
[Name of representative]
On behalf of the Claimant
Date: [Date of this Statement of Claim]
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