STATEMENT OF COUNTERCLAIM
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," "Counterclaim-Respondent")
— and —
[Respondent's name]
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Respondent/Counterclaim-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.
Introduction
This Statement of Counterclaim is filed as a document separate from the Statement of Defence. The particulars pleaded below are made pursuant to Article 17.3 of the HKIAC Administered Arbitration Rules (2024), which requires: (a) a statement of the facts supporting the counterclaim; (b) the points at issue; (c) the legal arguments supporting the counterclaim; and (d) the relief or remedy sought.
Article 17.3 textually places these particulars within the Statement of Defence itself rather than in a separately named "Statement of Counterclaim." Where, as here, the counterclaim is filed as a standalone document, that filing rests on the same Article 17.3 particulars and may be arranged under the Tribunal's Article 17.5 variation power or ordered as a further written statement under Article 20. This document does not address set-off; where set-off is pleaded, it is addressed in the Statement of Defence.
Confirm the basis for separate filing with the Tribunal before relying on this document's format.
The Parties
[Cross-reference the Statement of Defence rather than repeat, if filed jointly with or shortly after it.]
Jurisdiction
The Tribunal's jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence (dedicated jurisdiction provision: Article 19). Any counterclaim-specific jurisdictional point, if distinct, is pleaded here.
Factual Background
[Insert factual narrative supporting the counterclaim.]
Legal Grounds
[State the legal basis for the counterclaim, with authorities.]
Loss, Damage and Quantum
The Counterclaim-Claimant has suffered loss and damage in the amount of [amount claimed in the Counterclaim], particularised as follows: [quantum breakdown].
Interest is claimed at [interest rate on the Counterclaim] from [date from which interest is claimed on the Counterclaim].
Relief Sought
The Respondent/Counterclaim-Claimant requests that the Tribunal: (a) AWARD [amount claimed in the Counterclaim] on the Counterclaim; (b) AWARD interest as pleaded above; (c) ORDER the Claimant/Counterclaim-Respondent to pay the costs associated with the Counterclaim; and (d) GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
Pursuant to Article 17.4, the Respondent/Counterclaim-Claimant shall annex to this document all supporting materials on which it relies.
Exhibit No. | Description | Referenced at ¶ |
[Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
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