Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
SIAC Rules (2025, 7th Edition) — Statement of Defence
Archetype: Pleading
This document is prepared under the SIAC Rules (2025, 7th Edition), effective 1 January 2025. The Pleading archetype sets out bare material facts and traverse only, with no legal argument; contrast the Memorial archetype.
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 Rule 7.2 of the SIAC Rules (2025, 7th Edition), to include its Statement of Defence (and Statement of Counterclaim, if any) in its Response:
The Respondent elects to include its Statement of Defence in its Response to the Notice of Arbitration. This election is optional for the Respondent under Rule 7.2, in contrast to the Claimant's position under Rule 6.4.
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable with the Registrar or Tribunal before filing this Statement of Defence.
Jurisdiction Gate — Time-Bar Warning. Any jurisdictional objection is governed by Rule 31.2(a) of the SIAC Rules (2025, 7th Edition), which is dual-limbed: an objection to jurisdiction must be raised no later than in a Statement of Defence or, with respect to a counterclaim, in a Statement of Defence to a Counterclaim. Confirm which limb applies before filing.
STATEMENT OF DEFENCE
Where a counterclaim is pleaded within this document (see Section 12 below), the title should read "STATEMENT OF DEFENCE AND STATEMENT OF COUNTERCLAIM."
SIAC Case No.: [Insert case number, if assigned]
IN THE MATTER OF AN ARBITRATION UNDER THE SIAC RULES (2025, 7th EDITION)
BETWEEN
[Claimant's name] of
[Claimant's address]
("Claimant")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent")
Submitted on behalf of the Respondent by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Defence is submitted pursuant to Rule 33.3, pleading material facts only.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses that no third-party funding agreement exists as at the date of this Statement of Defence.
Where a third-party funding agreement exists, substitute the following for paragraph 2: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Respondent discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
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: The Respondent objects to jurisdiction on the following basis: [bare factual and legal 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 |
Material Facts (Respondent's Version)
[Bare facts only.]
Affirmative Defences
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About this template
What is this template?
This is a formal legal pleading for international arbitration proceedings that focuses on admitting or denying material facts. It is not a Memorial, as it excludes legal arguments and authorities in favor of bare factual positions. The document contains specific fields for Case Number, Third-Party Funding disclosure, and a General Traverse clause.
When should you use it?
Use this template when you are a Respondent in an arbitration administered by the Singapore International Arbitration Centre under the 2025 Rules and wish to file a concise factual response. If the case requires full legal arguments and witness evidence at the same time, use the SIAC Memorial archetype instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | States that the Respondent is submitting the pleading pursuant to Rule 33.3 to set out material facts. |
| 2 | Third-Party Funding Disclosure | Obliges the Respondent to disclose the existence or absence of a third-party funding agreement per Rule 38.1. |
| 4 | Jurisdiction | Identifies whether the Respondent raises a jurisdictional objection or admits the Tribunal's authority. |
| 5 | General Traverse | Enables the Respondent to deny every allegation in the Statement of Claim except those expressly admitted. |
| 8 | Affirmative Defences | Provides a section to plead set-off as a defence pursuant to Rule 33.3(b) separately from counterclaims. |
| 13 | Annexure Schedule | Directs the Respondent to attach all supporting documents not previously submitted as required by Rule 33.7. |
Who it's for
- a respondent in a SIAC arbitration responding to a Statement of Claim
- a party seeking to raise a jurisdictional objection under SIAC Rule 31.2
- a respondent pleading a counterclaim alongside their material fact traverse
- a party disclosing third-party funding status under SIAC Rule 38.1
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
file with SIAC Registrar; serve on Claimant
Law it's drafted under
Governed by
SIAC Rules (2025, 7th Edition)
Refers to
Rule 33.3
Refers to
Rule 38.1
Refers to
Rule 31.2(a)
Refers to
Rule 33.7
Jurisdiction
General
Singapore
Document info
GitLaw document. Document created on Sun Aug 9th, 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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