STATEMENT OF COUNTERCLAIM
Use this template where the Counterclaim is filed as a document standalone from the Statement of Defence. Where the Counterclaim is instead pleaded within the Statement of Defence itself, use the "Counterclaim" section of that template.
LCIA Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE LCIA ARBITRATION RULES (2020)
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]
Introduction
This Statement of Counterclaim is filed pursuant to Art. 15.3(ii) of the LCIA Arbitration Rules (2020), which permits the Respondent's Statement of Defence to be accompanied by a Statement of Counterclaim setting out in sufficient detail the relevant facts and legal submissions relied on, together with the relief claimed and all documents relied upon.
The Parties
The identity and description of the Parties are as set out in the Respondent's Statement of Defence.
Jurisdiction
The Tribunal's jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence.
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 [counterclaim quantum amount], particularised as follows: [insert quantum breakdown].
Interest is claimed at [counterclaim interest rate] from [counterclaim interest start date].
Relief Sought
The Respondent/Counterclaim-Claimant requests that the Tribunal:
AWARD [counterclaim quantum amount] on the Counterclaim;
AWARD interest as pleaded above;
ORDER the Claimant/Counterclaim-Respondent to pay the costs associated with the Counterclaim; and
GRANT such further or other relief as the Tribunal considers just.
Annexure Schedule
All documents relied upon by the Respondent/Counterclaim-Claimant accompany this Statement of Counterclaim, in accordance with Art. 15.3(ii), as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
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About this template
What is this template?
This is a formal filing for international arbitration and not a commercial contract. It contains specific placeholders for LCIA Case Numbers, quantum breakdowns, and a schedule for documentary exhibits. It is distinguished from a combined 'Defence and Counterclaim' by its standalone structure intended for memorial-style submissions.
When should you use it?
Use this filing when the procedural timetable or complexity of the claim requires a standalone Statement of Counterclaim under Art 15.3(ii). Use a 'Statement of Defence and Counterclaim' instead if pleading the counterclaim within the primary defensive response.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Invokes Art. 15.3(ii) of the LCIA Rules to submit a detailed counterclaim alongside the Statement of Defence. |
| 3 | Jurisdiction | Asserts that the Tribunal's authority over the counterclaim stems from the arbitration agreement pleaded in the main defense. |
| 6 | Loss, Damage and Quantum | Requires the Counterclaim-Claimant to specify the total quantum amount and the interest rate claimed from a specific date. |
| 7 | Relief Sought | Requests the Tribunal award specific quantum amounts, interest, and costs against the Counterclaim-Respondent. |
| 8 | Annexure Schedule | Lists all exhibits and documents relied upon by the Respondent in accordance with Art. 15.3(ii). |
Who it's for
- a respondent in an LCIA arbitration filing a counterclaim separate from their statement of defence
- legal representatives drafting formal memorials for international arbitration under 2020 LCIA Rules
How long it runs and how it's signed
Law it's drafted under
England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
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