Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF DEFENCE [AND COUNTERCLAIM]
DIAC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE DIAC ARBITRATION RULES 2022
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 Claimant included a statement of claim with its Request under Article 4.2, and the Respondent elects, pursuant to Article 5.2, to include its Statement of Defence with its Answer:
The Respondent elects to include the Statement of Defence referred to in Article 24.2 with its Answer dated [date of the Answer].
Jurisdiction Time-Bar Warning. Pursuant to Article 6.4, any jurisdictional objection must be raised no later than in the Statement of Defence.
Confirm before filing whether Section 4 needs to plead an objection.
Extension of Time. Pursuant to Article 5.7, the Centre may grant the Respondent an extension of up to 10 days for filing the Answer, conditioned on the extension application including the Respondent's comments on the number of arbitrators and (if applicable) its arbitrator nomination.
Introduction
This Statement of Defence is submitted pursuant to Article 24.2, pleading material facts only. Pursuant to Article 6.4, any jurisdictional objection must state its factual and legal basis even at the bare-facts pleading level.
The Parties
[Admit/deny identity of the parties as pleaded.]
Jurisdiction
No jurisdictional objection is raised.
Where the Respondent objects to jurisdiction, substitute the following for paragraph 3: Objection to jurisdiction on the following bare basis: [state factual and legal basis — no extended argument].
General Traverse
Save as expressly admitted below, the Respondent denies each allegation in the Statement of Claim.
Paragraph-by-Paragraph Reply
Use "Not Admitted" for allegations outside the Respondent's own knowledge, rather than a positive denial.
SoC ¶ | Allegation (summary) | Response |
¶1 | [summary] | [Admitted / Denied / Not Admitted] |
¶2 | [summary] | [Admitted / Denied / Not Admitted] |
¶[n] | [summary] | [Admitted / Denied / Not Admitted] |
Material Facts (Respondent's Version)
[Bare facts only.]
Affirmative Defences
Affirmative Defence 1: [bare basis].
Include the following paragraph only if the Respondent pleads set-off as a defence:
Set-Off. Pleaded in the amount of [set-off amount]. Article 1.1 of the Rules defines "Counterclaim" to include set-off submitted by the Respondent; this set-off may fall within the Counterclaim definition and its Article 5.5 registration fee.
Confirm the position with the Centre before treating it as fee-free.
Loss and Damage Response
Position on [amount claimed]: [admit / dispute].
Statement of Counterclaim (Pleading)
Include this section, and add "[AND COUNTERCLAIM]" to the title above, only if the Respondent pleads a counterclaim within this Statement of Defence.
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About this template
What is this template?
This is a formal pleading used to respond to claims in a DIAC arbitration and is not a contract or an initial Request for Arbitration. It contains specific sections for a general traverse and a paragraph-by-paragraph response table to categorize allegations as admitted or denied.
When should you use it?
Use this template when the Respondent needs to submit a detailed defense following a Statement of Claim or within the Answer period defined by Article 5. If the dispute has not yet reached the formal pleading stage, use a DIAC Answer to Request for Arbitration instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 3 | Jurisdiction | Requires the Respondent to raise any jurisdictional objection with its factual and legal basis as mandated by Article 6.4. |
| 6 | General Traverse | Includes a blanket denial of every allegation in the Statement of Claim unless a specific admission is expressly stated. |
| 9 | Set-Off | Allows the Respondent to plead a specific set-off amount which may be categorized as a Counterclaim under Rule 1.1. |
| 11 | Statement of Counterclaim | Establishes the Respondent's own claim for relief and requires payment of a registration fee within 7 days per Article 5.5. |
| 13 | Reservations | Reserves the right to supplement the pleading subject to Tribunal permission or party agreement required under Article 24.3. |
Who it's for
- a respondent in a Dubai International Arbitration Centre case responding to a formal Statement of Claim
- a party seeking to raise a jurisdictional objection or counterclaim under DIAC Rules 2022
- a legal representative submitting a formal pleading on behalf of a respondent
How long it runs and how it's signed
How long
Used once
Signed by
Respondent's Representative
Witness
Not required
Notarisation
Not required
Also needed
Pay registration fee for counterclaims within 7 days; Include Annexure Schedule with evidence
Law it's drafted under
Governed by
DIAC Arbitration Rules 2022
Refers to
Article 4.2
Refers to
Article 5.2
Refers to
Article 24.2
Jurisdiction
United Arab Emirates
General
Dubai (United Arab Emirates)
Document info
GitLaw document. Document created on Mon Aug 10th, 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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