Statement of Defence (Pleading) (ICC Rules) by OLL
Statement of Defence under the ICC Rules of Arbitration (2026), Standard track — Pleading archetype. Bare-facts defence and traverse only, with the same paragraph-by-paragraph reply structure and jurisdiction/set-off mechanics as the memorial version, condensed.
This document comes from OLL's library of vetted legal templates.
STATEMENT OF DEFENCE
ICC Case No.: [Case No.] Filed pursuant to: [Procedural Order No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026)
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 Notes
This Statement of Defence pleads material facts and traverse only. No Rules-level article prescribes its content; content and section order follow the Procedural Order. No rule-based default exists for the filing deadline. There is no elective merge of the Answer with this document.
Counterclaims. Article 6(4)-(5) ("Answer to the Request; Counterclaims") requires any counterclaim to be filed with the Answer, with a 30-day Claimant's reply. A counterclaim raised at the Answer stage is elaborated in a separate, standalone Statement of Counterclaim.
Jurisdiction. Article 7 gives the Tribunal authority to decide jurisdiction questions but fixes no filing deadline for raising the plea.
Confirm timing against the governing Procedural Order directly.
Introduction
This Statement of Defence is submitted pursuant to the Procedural Order governing this arbitration, pleading material facts only.
Include the following paragraph only if the Respondent has raised a counterclaim:
The Respondent has raised a counterclaim, first submitted with its Answer pursuant to Article 6(4). The counterclaim is pleaded in a separate Statement of Counterclaim; this document does not restate it.
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 4: Objection to jurisdiction on the following bare basis: [state basis — no 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:
Set-Off. Pleaded in the amount of [amount]. The ICC Rules have no distinct "set-off" concept — plead as, or with, a counterclaim under Article 6(4). Where India-seated, Section 23(2A) gives an express statutory basis.
Loss and Damage Response
Position on [amount]: [admit / dispute]. Early determination under Article 30 may be sought for manifestly unmeritorious claims.
Relief Sought
The Respondent seeks: (a) dismissal of the Statement of Claim; (b) costs; and (c) further or other relief.
Reservations
The Respondent reserves the right to amend or supplement this Statement of Defence, subject to the Procedural Order and the Article 25 new-claims cut-off.
Annexure Schedule
Annexure directions are determined by the Procedural Order; annexure content is minimal or deferred under this pleading archetype.
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent
Date: [date]
5.0 out of 5 on Google
Read reviewsAs seen in
Frequently asked questions
A template isn't binding on its own - like any contract, it becomes binding once it's properly completed and signed. Templates in our curated library are professionally drafted for US or UK law; review any template before you sign it.
Yes. Chat with GitLaw to edit any section, or make changes directly in the editor.
Yes, read about team plans here.
Describe what you need in the chat and GitLaw will draft it for you.
Templates in our curated library are professionally drafted for US or UK law. The wider library comes from the GitLaw community and public sources - a solid starting point, but check any template fits your situation before you rely on it.
Mostly US and UK law. Some templates use general commercial terms that work across jurisdictions, and many note which law they're written for.
It depends on the situation. Templates work well for routine business agreements. For anything involving significant money, complex IP, employment, or areas you're unsure about, it's worth getting professional advice before you sign. GitLaw provides templates and tools, not legal advice.
Open any template in GitLaw and describe the change you want in the chat — 'make clause 4 mutual' or 'add a 30-day notice period', for example. GitLaw drafts the revised language and shows it as a suggested edit. You accept, reject, or keep editing from there.
Yes. Upload a Word, PDF, or Markdown file and GitLaw will open it in the editor. You can review, edit, or chat with GitLaw about it the same way you would with any template from the library.
Trusted by thousands of businesses
From template to signed, in one place
Every template opens in an editor with an AI agent alongside it.
Open
Pick a template and open it. Nothing to download, and no credit card to start.
Free to open
Edit with AI
Describe your situation in chat and the agent adapts the wording, clause by clause.
Tracked changes you can review
Send and sign
Share it for negotiation, then collect signatures without leaving GitLaw.
eSign included
Built for your legal work, with practicing lawyers
Trained on 5.5K+ clauses and specialist areas of law. Built with a standards committee of independent lawyers.
As seen in
Start free
No sales calls, no credit card. Just chat with GitLaw.
GitLaw provides templates and tools, not legal advice. Templates are a starting point, not a substitute for advice on your situation - for anything significant, speak to a qualified lawyer.