Statement of Defence to Counterclaim (Memorial) (SIAC Rules) by OLL
SIAC Rules (2025, 7th Edition) — Statement of Defence to Counterclaim
Archetype: Memorial
This is the Claimant/Counterclaim-Respondent's reply to the Respondent's Statement of Counterclaim, submitted under Rule 33.4. This document is structurally a defence responding to the counterclaim's factual allegations, and follows the same general traverse and three-way admission structure as a Statement of Defence, notwithstanding its different title.
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
This arbitration may proceed under the Streamlined Procedure or the Expedited Procedure. If either applies, confirm the applicable timetable.
Jurisdiction Gate — Counterclaim. Rule 31.2(a) of the SIAC Rules (2025, 7th Edition) provides that an objection that the Tribunal does not have jurisdiction "with respect to a counterclaim" must be raised no later than in a Statement of Defence to a Counterclaim — the second limb of the jurisdictional-plea cut-off (the first limb, for the main claim, is the Statement of Defence itself). Any objection to the Tribunal's jurisdiction over the Counterclaim specifically must be raised in this document if not already raised.
STATEMENT OF DEFENCE TO 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," "Counterclaim-Respondent")
— and —
[Respondent's name] of
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Claimant/Counterclaim-Respondent by: [Representative's title] [Representative's name]
Date: [Date]
Introduction
This Statement of Defence to Counterclaim is submitted pursuant to Rule 33.4, in reply to the Statement of Counterclaim.
Rule 33.4 requires: (a) a statement of facts supporting the defence; (b) legal grounds or arguments supporting the defence, cross-claim, or set-off; and (c) the relief sought. Section index: (I) Third-Party Funding Disclosure; (II) Jurisdiction (Counterclaim); (III) General Traverse; (IV) Paragraph-by-Paragraph Reply; (V) Rule 33.4(a) — Facts Supporting the Defence; (VI) Rule 33.4(b) — Legal Grounds, Cross-Claim, or Set-Off; (VII) Rule 33.4(c) — Relief Sought.
Third-Party Funding Disclosure
Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Claimant/Counterclaim-Respondent discloses that no third-party funding agreement exists as at the date of this document.
Where a third-party funding agreement exists, substitute the following for paragraph 3: Pursuant to Rule 38.1 of the SIAC Rules (2025, 7th Edition), the Claimant/Counterclaim-Respondent discloses the existence of a third-party funding agreement. The identity and contact details of the funder are [funder details].
Jurisdiction (Counterclaim)
No objection is raised to the Tribunal's jurisdiction over the Counterclaim.
Where the Claimant/Counterclaim-Respondent objects to jurisdiction over the Counterclaim, substitute the following for paragraph 4: The Claimant/Counterclaim-Respondent objects to the Tribunal's jurisdiction over the Counterclaim on the following factual and legal basis: [state basis]. This objection is raised within the deadline identified in Section 1 above.
General Traverse
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