Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
SIAC Rules (2025, 7th Edition) — Statement of Counterclaim
Archetype: Pleading
This standalone document is for use where the counterclaim is filed as its own document rather than merged into the Statement of Defence, pleading material facts only. The SIAC Rules (2025, 7th Edition) have no free-standing "Statement of Counterclaim" article; the citation basis is Rule 33.3, the Statement of Defence provision, which expressly extends to the counterclaim.
STATEMENT OF COUNTERCLAIM
SIAC Case No.: [Insert case number, if assigned]
IN THE MATTER OF AN ARBITRATION UNDER THE SIAC RULES (2025, 7th EDITION)
BETWEEN
[Claimant's name] of
[Claimant's address]
("Claimant," "Counterclaim-Respondent")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Respondent/Counterclaim-Claimant by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Counterclaim pleads material facts only. Set-off, if pleaded, is addressed only in the Statement of Defence and is not part of this document.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Counterclaim-Claimant discloses that no third-party funding agreement exists.
Where a third-party funding agreement exists, substitute the following for paragraph 2: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Counterclaim-Claimant discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
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] [quantified].
Interest claimed at [interest rate] from [date].
Relief Sought
The Respondent/Counterclaim-Claimant seeks: (a) [amount]; (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 Rule 33.5.
Annexure Schedule
Pursuant to Rule 33.7 of the SIAC Rules (2025, 7th Edition), this submission shall be accompanied by copies of all supporting documents that have not previously been submitted by any party. The Tribunal may, after considering the views of the parties, further direct that this submission be accompanied by supporting witness statements and expert reports.
Respectfully submitted,
[Representative's title] [Representative's 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 legal pleading used to assert a respondent's own claims against the claimant in a SIAC arbitration. It is not a combined Statement of Defence and Counterclaim; it focus strictly on the material facts and relief sought for the cross-action. It contains specific mandatory disclosures regarding third-party funding and annexure schedules required by the 2025 rules.
When should you use it?
Use this when the counterclaim is complex enough to require a standalone document rather than a section within the Statement of Defence. If you are only defending against the claimant's allegations, use a Statement of Defence instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 2 | Third-Party Funding Disclosure | Discloses the existence or absence of a third-party funding agreement and funder identity pursuant to Rule 38.1. |
| 4 | Jurisdiction | Establishes that the counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence. |
| 7 | Loss and Damage | Requires the respondent to quantify the loss amount and specify the interest rate and start date for the claim. |
| 8 | Relief Sought | Lists the specific amounts, interest, and costs the Counterclaim-Claimant requests from the Tribunal. |
| 9 | Reservations | Expressly reserves the right to amend or supplement the pleading according to Rule 33.5. |
| 10 | Annexure Schedule | Mandates the submission of copies of all supporting documents not previously submitted by any party per Rule 33.7. |
Who it's for
- a respondent in a SIAC arbitration filing a standalone counterclaim
- legal representatives drafting pleadings under the 2025 SIAC Rules
- a party seeking to quantify damages and interest against an original claimant
How long it runs and how it's signed
How long
Used once
Signed by
Representative of Respondent/Counterclaim-Claimant
Witness
Not required
Notarisation
Not required
Also needed
file with the SIAC Secretariat; include annexure of supporting documents
Law it's drafted under
Governed by
SIAC Rules (2025, 7th Edition)
Refers to
Rule 33.3 SIAC Rules
Required by
Rule 38.1 SIAC Rules
Refers to
Rule 33.5 SIAC Rules
Refers to
Rule 33.7 SIAC Rules
Jurisdiction
Singapore
General
Document info
GitLaw document. Document created on Sun Aug 9th, 2026. Last updated on Mon Aug 10th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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