UNCITRAL Arbitration Rules (2021), Article 21(3)–(4) — Pleading Archetype
The UNCITRAL Rules do not provide for a separately-titled "Statement of Counterclaim"; a counterclaim is raised under Article 21(3) and, by operation of Article 21(4), is subject to the same content requirements as a statement of claim. This is a standalone counterclaim document, pleading archetype: material facts only, with no argument and no evidence inline.
COUNTERCLAIM
[Case No.: [Case number, if allocated]]
IN THE MATTER OF AN ARBITRATION UNDER THE UNCITRAL ARBITRATION RULES (2021)
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, e.g. Counsel for the Respondent] [Name of representative]
Date: [Date of this Counterclaim]
Introduction
This Counterclaim is submitted pursuant to Art. 21(3) of the UNCITRAL Arbitration Rules (2021), pleading material facts only. This document pleads a counterclaim proper, distinct from a set-off raised purely as a defence.
The Parties
[Identify the Parties, cross-referring to the Statement of Defence rather than repeating, where appropriate.]
Jurisdiction
Jurisdiction over the Counterclaim arises from the same arbitration agreement pleaded in the Statement of Defence. Plead any counterclaim-specific jurisdictional point here only if it is distinct.
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 [counterclaim quantum amount].
Interest claimed at [counterclaim interest rate] from [counterclaim interest start date].
Relief Sought
The Respondent/Counterclaim-Claimant seeks: (a) [counterclaim quantum 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 Counterclaim pursuant to Art. 22.
Annexure Schedule
The exhibit schedule is minimal or deferred to a later stage under this pleading archetype.
Respectfully submitted,
[Representative's title]
[Name of representative]
On behalf of the Respondent/Counterclaim-Claimant
Date: [Date of this Counterclaim]
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