UNCITRAL Arbitration Rules (2021) — Pleading Archetype
This archetype pleads material facts and a traverse only, with no legal argument and no evidence inline.
STATEMENT OF DEFENCE
If Section 9 (Statement of Counterclaim) below is included, the title above should read: "STATEMENT OF DEFENCE AND STATEMENT OF COUNTERCLAIM".
[Case No.: [Case number, if allocated]]
IN THE MATTER OF AN ARBITRATION UNDER THE UNCITRAL ARBITRATION RULES (2021)
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, e.g. Counsel for the Respondent] [Name of representative]
Date: [Date of this Statement of Defence]
Introduction
Include the following Election Notice only if the Respondent elects, pursuant to Art. 21(1) (second sentence), to treat its Response to the Notice of Arbitration as its Statement of Defence:
"Pursuant to Art. 21(1), the Respondent elects to treat its Response to the Notice of Arbitration dated [date] as its Statement of Defence, supplemented as set out below."
This Statement of Defence is submitted pursuant to Art. 21 of the UNCITRAL Arbitration Rules (2021), pleading material facts only.
The Parties
[Admit / deny identity of the parties as pleaded.]
Jurisdiction
[If no jurisdictional objection is raised: "No jurisdictional objection is raised." If a jurisdictional objection is raised: "The Respondent objects to jurisdiction on the following basis: [bare factual and legal basis — no argument]." Pursuant to Art. 23(2), any objection must be raised no later than this Statement of Defence, or it is liable to be treated as time-barred.]
General Traverse
Save as expressly admitted below, the Respondent denies each allegation in the Statement of Claim.
Paragraph-by-Paragraph Reply
For each paragraph, the Respondent's response is stated as ADMITTED, DENIED, or NOT ADMITTED.
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, no argument.]
Affirmative Defences
Affirmative Defence 1: [bare basis, no argument].
[Include the following paragraph only if the Respondent pleads set-off as a defence: "Set-Off. Set-off pleaded in the amount of [set-off amount], as a defence." Set-off pleaded here is distinct from a counterclaim pleaded under Section 9 below.]
Loss and Damage Response
The Respondent's position on [quantum amount]: [admit / dispute].
Statement of Counterclaim
Include this Section only if the Respondent raises a counterclaim within this Statement of Defence, pursuant to Art. 21(3). Because a counterclaim is a claim, this Section reuses the pleading-archetype Statement of Claim element set. If the counterclaim is instead to be filed as a separate document, omit this Section and use the standalone Counterclaim (Pleading) template.
Material facts supporting the counterclaim. [Insert.]
Breach alleged. [Bare characterisation.]
Relief and quantum sought. [counterclaim quantum amount].
Relief Sought
The Respondent seeks: (a) dismissal of the Statement of Claim; (b) [if Section 9 above is included:] [counterclaim quantum amount] on the Counterclaim; (c) costs; and (d) further or other relief.
Reservations
The Respondent reserves the right to amend or supplement this Statement of Defence pursuant to Art. 22, and to plead further facts, legal grounds, and evidence at the appropriate stage.
Annexure Schedule
The exhibit schedule is minimal or deferred under this pleading archetype.
Respectfully submitted,
[Representative's title]
[Name of representative]
On behalf of the Respondent
Date: [Date of this Statement of Defence]
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