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 elects to treat the Notice of Arbitration dated [date of the Notice of Arbitration] as its Statement of Claim.
The Tribunal may, pursuant to Article 16.4, vary the content requirements for this document.
Before filing, confirm that no Procedural Order has varied this structure.
Introduction
This Statement of Claim is submitted pursuant to Article 16, pleading material facts only. A bare pleading of material facts corresponds to the particular at Article 16.2(a).
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 arbitration agreement at [clause reference], seated at [seat of arbitration]. Dedicated jurisdiction provision: Article 19.
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 amend or supplement this Statement of Claim pursuant to Article 18, and to plead further facts, legal grounds, and evidence at the appropriate stage.
Annexure Schedule
Pursuant to Article 16.3, the Claimant shall annex all supporting materials on which it relies. This obligation applies notwithstanding the otherwise minimal exhibit convention of the pleading archetype.
Confirm scope with the Tribunal if seeking to minimise the exhibit set for this filing.
Exhibit No. | Description | Referenced at ¶ |
C-1 | [Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant
Date: [date]
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