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 as its Statement of Defence:
The Respondent elects to treat its Answer dated [date of the Answer] as its Statement of Defence.
The Tribunal may, pursuant to Article 17.5, vary the content requirements for this document.
Jurisdiction Time-Bar Warning. Pursuant to Article 19.3, a jurisdictional objection must be raised, if possible, in the Answer to the Notice of Arbitration, and no later than in the Statement of Defence (or, for a counterclaim, in the Defence to the Counterclaim).
Confirm before filing whether Section 4 needs to plead an objection.
Introduction
This Statement of Defence is submitted pursuant to Article 17, pleading material facts only. Pursuant to Article 17.2, any jurisdictional or constitution 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 or the Tribunal's constitution, substitute the following for paragraph 3: Objection to jurisdiction/constitution 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 |
[summary] | [Admitted / Denied / Not Admitted] | |
[summary] | [Admitted / Denied / Not Admitted] | |
[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. Pursuant to Article 17.3, pleaded in the amount of [set-off amount].
Loss and Damage Response
Position on [amount claimed]: [admit / dispute].
Statement of Counterclaim
Include this section, and add "[AND COUNTERCLAIM]" to the title above, only if the Respondent pleads a counterclaim within this Statement of Defence. Pleaded pursuant to Article 17.3, on the same footing as set-off and cross-claim.
Material facts supporting the counterclaim. [Insert.]
Breach alleged. [Bare characterisation.]
Relief and quantum. [amount claimed in the Counterclaim].
Relief Sought
The Respondent seeks: (a) dismissal of the Statement of Claim; (b) [amount claimed in the Counterclaim] on the Counterclaim; (c) costs; and (d) further or other relief.
Delete limb (b) if no counterclaim is pleaded, and re-letter accordingly.
Reservations
The Respondent reserves the right to amend or supplement this Statement of Defence pursuant to Article 18.
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