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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