Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF DEFENCE [AND 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")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Respondent 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.
Preliminary Matters
Include the following paragraph only if the Respondent elects, pursuant to Article 17.1, to treat its Answer to the Notice of Arbitration as its Statement of Defence:
The Respondent hereby elects to treat its Answer to the Notice of Arbitration dated [date of the Answer] as its Statement of Defence, supplemented as set out below.
The Tribunal may, pursuant to Article 17.5, vary the content requirements set out below for this Statement of Defence.
Jurisdiction Time-Bar Warning. Pursuant to Article 19.3, a plea that the Tribunal lacks jurisdiction must be raised, if possible, in the Answer to the Notice of Arbitration, and no later than in this Statement of Defence (or, in respect of a counterclaim, in the Defence to the Counterclaim). A jurisdictional plea not raised by this document (or, where applicable, by the Answer) may be treated as time-barred.
Confirm before filing whether Section 4 below needs to plead an objection.
Introduction
This Statement of Defence is submitted pursuant to Article 17, in reply to the particulars pleaded under Article 16.2(a)–(c). Where a jurisdictional or constitution objection is raised, Article 17.2 requires that it contain its factual and legal basis.
Section index: (I) the Parties; (II) Jurisdiction; (III) General Traverse; (IV) Paragraph-by-Paragraph Reply; (V) Factual Background; (VI) Legal Grounds; (VII) Affirmative Defences; (VIII) Quantum Response; (IX) Statement of Counterclaim, if pleaded; (X) Relief Sought; (XI) Annexure Schedule.
The Parties
Paragraphs [ ] of the Statement of Claim as to the identity of the Parties are ADMITTED, save as pleaded below.
Jurisdiction
The Respondent does not object to the Tribunal's jurisdiction.
Where the Respondent objects to the Tribunal's jurisdiction or its constitution, substitute the following for paragraph 3:
"The Respondent objects to the Tribunal's jurisdiction (or to its constitution) on the following factual and legal basis, pursuant to Article 17.2: [state factual basis] and [state legal basis]."
General Traverse
Save as expressly admitted in this Statement of Defence, the Respondent denies each and every allegation made in the Statement of Claim as if set out here and traversed individually.
Paragraph-by-Paragraph Reply
Use "Not Admitted" for allegations outside the Respondent's own knowledge, rather than a positive denial.
SoC ¶ | Allegation (summary) | Response |
[summary] | [Admitted / Denied / Not Admitted] | |
[summary] | [Admitted / Denied / Not Admitted] | |
¶ | [summary] | [Admitted / Denied / Not Admitted] |
Factual Background
[Respondent's factual narrative, cross-referenced to exhibits.]
Legal Grounds
[Respondent's legal argument in answer to each cause of action.]
Affirmative Defences
Affirmative Defence 1: [basis].
Affirmative Defence 2: [if applicable].
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About this template
What is this template?
This is a formal legal filing used in international arbitration to respond to a Statement of Claim. It contains a paragraph-by-paragraph reply table, a section for affirmative defences, and a dedicated schedule for annexing exhibits. It is not an informal response or a simple notification of intent to defend.
When should you use it?
Use this template after receiving a Statement of Claim in an arbitration governed by the 2024 HKIAC Rules. If responding only to the initial Notice of Arbitration before the tribunal is formed, use an Answer to the Notice of Arbitration instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 3 | Jurisdiction | Allows the Respondent to either accept or object to the Tribunal's jurisdiction pursuant to Article 17.2 and Article 19.3. |
| 4 | General Traverse | Denies every allegation in the Statement of Claim unless it is expressly admitted within this filing. |
| 9 | Affirmative Defences | Sets out specific legal bases for the Respondent to avoid liability even if the Claimant's allegations are proven. |
| 11 | Statement of Counterclaim | Permits the Respondent to plead a counterclaim for specific relief or quantum pursuant to Article 17.3. |
| 12 | Relief Sought | Requests the Tribunal to dismiss the original claim, award counterclaim amounts, and order the Claimant to pay arbitration costs. |
| 13 | Annexure Schedule | Requires the Respondent to list and attach all supporting materials relied upon as required by Article 17.4. |
Who it's for
- a respondent defending against a claim in an HKIAC administered arbitration
- legal counsel drafting a response to a formal Statement of Claim
- a party asserting a counterclaim or set-off within arbitration proceedings
- a respondent raising a jurisdictional objection before the arbitration tribunal
How long it runs and how it's signed
How long
Used once
Signed by
Respondent Representative
Witness
Not required
Notarisation
Not required
Also needed
renumber sequentially before submission; annex all supporting materials; file according to HKIAC procedural timelines
Law it's drafted under
Governed by
HKIAC Administered Arbitration Rules (2024)
Refers to
Article 16.2(a)–(c)
Refers to
Article 17
Refers to
Article 19.3
Jurisdiction
Hong Kong
General
Document info
GitLaw document. Document created on Mon Aug 10th, 2026. Last updated on Tue Aug 11th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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