UNCITRAL Arbitration Rules (2021) — Pleading Archetype
This archetype pleads material facts only. It contains no legal argument and no evidence; submissions and evidence follow separately according to the Tribunal's procedural timetable. For a document containing full argument and evidence inline, see the Memorial 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) and pleads material facts only.
This Statement of Claim is structured as follows: (I) the Parties; (II) Jurisdiction; (III) Material Facts; (IV) Breaches Alleged; (V) Loss and Damage; (VI) Relief Sought.
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.]
State facts only, cross-referenced to documents by number where relevant. Argument and analysis are reserved for a later stage of the proceedings.
Breaches Alleged
[Bare characterisation of the cause of action — e.g. "The Respondent breached clause X of the Agreement by [conduct]." No authorities, no argument.]
Loss and Damage
The Claimant has suffered loss and damage in the amount of [quantum amount].
The Claimant claims interest at [interest rate] from [interest start date].
Relief Sought
The Claimant seeks: (a) payment of [quantum amount]; (b) interest as pleaded above; (c) costs; and (d) further or other relief.
Reservations
The Claimant reserves the right to amend or supplement this Statement of Claim pursuant to Art. 22, and to plead further facts, legal grounds, and evidence at the appropriate stage of the proceedings.
Annexure Schedule
The exhibit schedule is minimal or deferred to the memorial/evidentiary stage under this pleading archetype. This deferral does not extend to Art. 20(3), which requires that a copy of the contract or other instrument out of which the dispute arises, and of the arbitration agreement, be annexed to this Statement of Claim regardless of archetype.
Respectfully submitted,
[Representative's title]
[Name of representative]
On behalf of the Claimant
Date: [Date of this Statement of Claim]
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