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, s 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 with its Request:
The Claimant elects to include the Statement of Claim referred to in Article 24.1 with its Request dated [date of the Request].
Absent inclusion with the Request, Article 24.1 requires filing within such time as the Tribunal determines after consultation with the parties; there is no fixed default period.
Introduction
This Statement of Claim is submitted pursuant to Article 24.1 of the DIAC Arbitration Rules 2022, administered by the Dubai International Arbitration Centre, pleading material facts only.
The Parties
The Claimant is [Claimant's name], [brief description].
The Respondent is [Respondent's name], [brief description].
Jurisdiction
The Tribunal has jurisdiction pursuant to the agreement to arbitrate at [clause reference], seated at [seat of arbitration]. Dedicated provision: Article 6.1; objection deadline (if any): Article 6.4 — no later than the Statement of Defence.
Material Facts
[Fact 1.]
[Fact 2.]
[Fact 3.]
Breaches Alleged
[Bare characterisation of the cause of action, no authorities.]
Loss and Damage
Loss and damage of [amount claimed] [quantified].
Interest claimed at [interest rate] from [date from which interest is claimed].
Relief Sought
The Claimant seeks: (a) [amount claimed]; (b) interest as pleaded; (c) costs; (d) further or other relief.
Reservations
The Claimant reserves the right to plead further facts, legal grounds and evidence, and to amend or supplement this Statement of Claim, subject to Article 24.3 — new claims after the Statement of Claim require either Tribunal permission (having regard to the nature of the new claim, the stage of the arbitration, delay, and prejudice) or the agreement of the parties.
Annexure Schedule
Pursuant to Article 24.1, the evidence to be submitted with the Statement of Claim is as determined by the Tribunal.
Confirm the Tribunal's actual direction on scope before finalising this schedule.
Exhibit No. | Description | Referenced at ¶ |
[Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant
Date: [date]
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