Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Archetype: Pleading
This document is prepared under the SIAC Rules (2025, 7th Edition), effective 1 January 2025. The Pleading archetype sets out bare material facts only, with no legal argument or evidentiary analysis; contrast the Memorial archetype.
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.
STATEMENT OF CLAIM
SIAC Case No.: [Insert case number, if assigned]
IN THE MATTER OF AN ARBITRATION UNDER THE SIAC RULES (2025, 7th EDITION)
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] [Representative's name]
Date: [Date]
Introduction
This Statement of Claim is submitted pursuant to Rule 33.1–33.2 of the SIAC Rules (2025, 7th Edition), pleading material facts only.
Include the following paragraph only if the Claimant elects, pursuant to Rule 6.4 of the SIAC Rules (2025, 7th Edition), to submit its Statement of Claim together with its Notice of Arbitration:
The Claimant elects to submit this Statement of Claim together with the Notice of Arbitration.
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable with the Registrar or Tribunal before filing this Statement of Claim, as this template assumes the standard procedural timetable.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Claimant discloses that no third-party funding agreement exists as at the date of this Statement of Claim.
Where a third-party funding agreement exists, substitute the following for paragraph 2: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Claimant discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
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].
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] [quantified].
Interest claimed at [interest rate] from [date].
Relief Sought
The Claimant seeks: (a) [amount]; (b) interest as pleaded; (c) costs; and (d) further or other relief.
Reservations
The Claimant reserves the right to amend or supplement this Statement of Claim pursuant to Rule 33.5 (leave of Tribunal, granted unless inappropriate having regard to timing, prejudice, or the scope of the arbitration agreement), and to plead further facts, legal grounds, and evidence at the appropriate stage.
Annexure Schedule
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About this template
What is this template?
This document is a pleading archetype for use in SIAC arbitrations that sets out bare material facts without legal argument or evidentiary analysis. It is distinct from a Memorial archetype which would include legal authorities and witness statements. The document contains specific placeholders for third-party funding disclosures and the jurisdictional seat overlay.
When should you use it?
Use this template when initiating the substantive phase of an arbitration under the SIAC Rules (2025). Use a Memorial template instead if the procedural order requires full legal arguments and evidence to be submitted alongside the facts.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | States that the submission is made pursuant to Rule 33.1–33.2 of the SIAC Rules (2025, 7th Edition) and contains material facts only. |
| 2 | Third-Party Funding Disclosure | Obliges the Claimant to disclose the existence of any third-party funding agreement and the funder's identity under Rule 38.1. |
| 4 | Jurisdiction | Identifies the specific clause reference in the arbitration agreement that grants the Tribunal authority and names the seat of arbitration. |
| 8 | Relief Sought | Lists the specific amounts, interest, and costs the Claimant seeks from the Tribunal as a result of the alleged breaches. |
| 9 | Reservations | Reserves the Claimant's right to amend the claim under Rule 33.5 with leave of the Tribunal. |
| 10 | Annexure Schedule | Requires the attachment of supporting documents not previously submitted as mandated by Rule 33.7 of the SIAC Rules. |
Who it's for
- a claimant filing a statement of claim in a SIAC arbitration
- a legal representative submitting material facts under the 2025 SIAC Rules
- parties electing to submit a statement of claim with a notice of arbitration
How long it runs and how it's signed
How long
Used once
Signed by
Representative's name
Witness
Not required
Notarisation
Not required
Also needed
renumber paragraphs sequentially before submission
Law it's drafted under
Governed by
SIAC Rules (2025, 7th Edition)
Jurisdiction
Singapore
General
Document info
GitLaw document. Document created on Sun Aug 9th, 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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