Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF DEFENCE [AND COUNTERCLAIM]
["AND COUNTERCLAIM" appears in the title only where the Respondent raises a Counterclaim in this filing.]
LCIA Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE LCIA ARBITRATION RULES (2020)
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]
Introduction
This Statement of Defence is submitted pursuant to Art. 15.3 of the LCIA Arbitration Rules (2020), pleading material facts only, within 28 days of the Respondent's receipt of the Statement of Case or of the Claimant's election under Art. 15.2.
The Parties
[Identity of the parties as pleaded.]
Jurisdiction
No jurisdictional objection is raised. [Where the Respondent objects to the Tribunal's jurisdiction, substitute for this paragraph: "The Respondent objects to the Tribunal's jurisdiction on the following bare basis: [state basis — no argument]. This objection is raised no later than the time for this Statement of Defence, in accordance with Art. 23.3 of the LCIA Rules."]
General Traverse
Save as expressly admitted below, the Respondent denies each allegation in the Statement of Case.
Paragraph-by-Paragraph Reply
Statement of Case ¶ | Allegation (summary) | Response |
Material Facts
(Respondent's Version)
[Bare facts only.]
Affirmative Defences
Affirmative Defence 1: [bare basis].
Include the following paragraph only where the Respondent pleads a set-off: "Set-Off. Pleaded in the amount of [set-off amount]. The LCIA Rules do not provide a distinct set-off mechanism; this is accordingly pleaded as an ordinary affirmative defence, distinct from a Counterclaim."
Loss and Damage Response
Position on [quantum amount]: [admit / dispute].
Counterclaim
[Include this Section only where the Respondent raises a Counterclaim in this Statement of Defence, pursuant to Art. 15.3(ii).]
Material facts supporting the counterclaim. [Insert.]
Breach alleged. [Bare characterisation.]
Relief and quantum. [counterclaim quantum amount].
Relief Sought
The Respondent seeks:
dismissal of the Statement of Case;
[where a Counterclaim is pleaded] [counterclaim quantum amount] on the Counterclaim;
costs; and
further or other relief.
Reservations
The Respondent reserves the right to amend or supplement this Statement of Defence at the appropriate stage of the proceedings, subject to any directions of the Tribunal under Art. 15.7/15.8.
Annexure Schedule
All documents relied upon by the Respondent (including, where applicable, in support of the Counterclaim) accompany this Statement of Defence, in accordance with Art. 15.3(ii), as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent
Date: [date]
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About this template
What is this template?
This is a formal legal pleading used to respond to a Statement of Case in commercial arbitration. It contains a paragraph-by-paragraph response table, a section for affirmative defences, and a structured annexure schedule for exhibits. It is not a notice of arbitration or a generic court filing.
When should you use it?
Use this template when a Respondent needs to file a substantive defence within the 28-day limit set by LCIA Art. 15.3. Use a Response to Request for Arbitration instead if the tribunal has not yet been constituted or the Statement of Case has not been filed.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | States the Statement of Defence is submitted pursuant to Art. 15.3 of the LCIA Rules within 28 days of receipt. |
| 3 | Jurisdiction | Requires the Respondent to raise any jurisdictional objection no later than this filing according to Art. 23.3. |
| 4 | General Traverse | Establishes a default denial of every allegation in the Statement of Case unless expressly admitted. |
| 7 | Affirmative Defences | Provides a section for pleading specific legal bases for defense, including a distinct mechanism for set-off amounts. |
| 9 | Counterclaim | Includes material facts and relief sought for a Counterclaim raised pursuant to Art. 15.3(ii). |
| 11 | Reservations | Reserves the Respondent's right to amend pleadings subject to Tribunal directions under Art. 15.7 or Art. 15.8. |
Who it's for
- a party responding to a Statement of Case in an LCIA arbitration
- a Respondent pleading a set-off or counterclaim in institutional arbitration
- legal representatives drafting formal pleadings under the 2020 LCIA Rules
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Respondent
Witness
Not required
Notarisation
Not required
Also needed
Serve within 28 days of Statement of Case receipt; Include Annexure Schedule of supporting documents
Law it's drafted under
Governed by
LCIA Arbitration Rules (2020)
Required by
LCIA Rules Art. 15.3
Refers to
LCIA Rules Art. 23.3
England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
Jurisdiction
England & Wales
General
Document info
GitLaw document. Document created on Sun Aug 9th, 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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