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 pleads material facts only. The counterclaim is governed by Article 17.3 of the HKIAC Administered Arbitration Rules (2024). This document does not address set-off; where set-off is pleaded, it is addressed in the Statement of Defence.
The Parties
[Cross-reference the Statement of Defence rather than repeat.]
Jurisdiction
Jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence.
Material Facts
[Bare facts supporting the counterclaim — no argument.]
Breach Alleged
[Bare characterisation of the counterclaim's cause of action.]
Loss and Damage
Loss and damage of [amount claimed in the Counterclaim] [quantified].
Interest claimed at [interest rate on the Counterclaim] from [date from which interest is claimed on the Counterclaim].
Relief Sought
The Respondent/Counterclaim-Claimant seeks: (a) [amount claimed in the Counterclaim]; (b) interest as pleaded; (c) costs of the Counterclaim; and (d) further or other relief.
Reservations
The Respondent/Counterclaim-Claimant reserves the right to amend or supplement this Statement of Counterclaim pursuant to Article 18.
Annexure Schedule
Pursuant to Article 17.4, the Respondent/Counterclaim-Claimant shall annex all supporting materials on which it relies.
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
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