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]
5.0 out of 5 on Google
Read reviewsAs seen in
About this template
What is this template?
This is a formal legal pleading used in international arbitration. It establishes the Respondent's own claim against the Claimant, distinct from a mere defence or set-off. It contains specific placeholders for Article 17 and Article 18 compliance and a mandatory annexure schedule for supporting evidence.
When should you use it?
Use this when a respondent in an HKIAC-administered case has an independent cause of action to assert against the claimant. Use the Statement of Defence if you only intend to deny the claimant's allegations without seeking independent relief.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Invokes Article 17.3 of the HKIAC Rules (2024) and distinguishes the counterclaim from any set-off pleaded in the Defence. |
| 3 | Jurisdiction | Asserts that jurisdiction over the Counterclaim derives from the same arbitration agreement pleaded in the main Statement of Defence. |
| 6 | Loss and Damage | Requires the Counterclaim-Claimant to state a quantified amount of loss and specify the interest rate and commencement date. |
| 7 | Relief Sought | Lists the specific demands including the principal amount, interest, costs of the Counterclaim, and any other further relief. |
| 8 | Reservations | Preserves the Respondent's right to amend or supplement the pleading in accordance with Article 18 of the HKIAC Rules. |
| 9 | Annexure Schedule | Obliges the Respondent to attach all supporting materials relied upon as required by Article 17.4. |
Who it's for
- a respondent in HKIAC arbitration needing to bring a cross-claim against the claimant
- legal counsel drafting formal pleadings under the 2024 HKIAC Administered Arbitration Rules
- a party seeking quantified damages and interest in an active Hong Kong based arbitration
How long it runs and how it's signed
Law it's drafted under
Frequently asked questions
A template isn't binding on its own - like any contract, it becomes binding once it's properly completed and signed. Templates in our curated library are professionally drafted for US or UK law; review any template before you sign it.
Yes. Chat with GitLaw to edit any section, or make changes directly in the editor.
Yes, read about team plans here.
Describe what you need in the chat and GitLaw will draft it for you.
Templates in our curated library are professionally drafted for US or UK law. The wider library comes from the GitLaw community and public sources - a solid starting point, but check any template fits your situation before you rely on it.
Mostly US and UK law. Some templates use general commercial terms that work across jurisdictions, and many note which law they're written for.
It depends on the situation. Templates work well for routine business agreements. For anything involving significant money, complex IP, employment, or areas you're unsure about, it's worth getting professional advice before you sign. GitLaw provides templates and tools, not legal advice.
Open any template in GitLaw and describe the change you want in the chat — 'make clause 4 mutual' or 'add a 30-day notice period', for example. GitLaw drafts the revised language and shows it as a suggested edit. You accept, reject, or keep editing from there.
Yes. Upload a Word, PDF, or Markdown file and GitLaw will open it in the editor. You can review, edit, or chat with GitLaw about it the same way you would with any template from the library.
Trusted by 5,000+ businesses
From template to signed, in one place
Every template opens in an editor with an AI agent alongside it.
Open
Pick a template and open it. Nothing to download, and no credit card to start.
Free to open
Edit with AI
Describe your situation in chat and the agent adapts the wording, clause by clause.
Tracked changes you can review
Send and sign
Share it for negotiation, then collect signatures without leaving GitLaw.
eSign included
Built for your legal work,
with practicing lawyers
Trained on 5,500+ clauses and specialist areas of law. Built with a standards committee of independent lawyers.
As seen in
Ready to get started?
No sales calls, no credit card. Just chat with GitLaw.
GitLaw provides templates and tools, not legal advice. Templates are a starting point, not a substitute for advice on your situation - for anything significant, speak to a qualified lawyer.