Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Statement of Reply to Defence to Counterclaim (Pleading) (LCIA Rules) by OLL
Open Legal LibraryUpdated 11 Aug 2026
STATEMENT OF REPLY TO THE DEFENCE TO COUNTERCLAIM
[This template applies only where: (1) the Respondent has pleaded a Counterclaim in its Statement of Defence under Art. 15.3; and (2) the Claimant's Statement of Reply included a Statement of Defence to Counterclaim under Art. 15.4. This document is filed by the Respondent, as Counterclaim-Claimant.]
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," "Counterclaim-Respondent")
— and —
[Respondent's name]
[Respondent's address]
("Respondent," "Counterclaim-Claimant")
Submitted on behalf of the Respondent/Counterclaim-Claimant by: [Representative's title and name]
Date: [date]
Introduction
This Statement of Reply to the Defence to Counterclaim is submitted pursuant to Art. 15.5 of the LCIA Arbitration Rules (2020), pleading material facts only in response to new matters raised in the Claimant's Defence to Counterclaim, within 28 days of the Respondent's receipt of the Claimant's Statement of Reply.
Save as the Tribunal may otherwise direct, this document is the last written statement to be filed in the arbitration, pursuant to Art. 15.6 of the LCIA Rules.
Reply to the Defence to Counterclaim
(Material Facts Only)
[Bare facts addressing new matters raised in the Defence to Counterclaim — no argument.]
[Bare response to any affirmative defences or set-off pleaded by the Claimant against the Counterclaim.]
Relief Sought:
The Respondent/Counterclaim-Claimant maintains its request for:
[counterclaim quantum amount] on the Counterclaim;
interest as pleaded in the Statement of Defence/Counterclaim;
costs of the Counterclaim; and
further or other relief.
Annexure Schedule
All documents relied upon by the Respondent/Counterclaim-Claimant accompany this Statement of Reply to the Defence to Counterclaim, in accordance with Art. 15.5, as follows:
Exhibit No. | Description | Referenced at ¶ |
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counterclaim-Claimant
Date: [date]
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About this template
What is this template?
This is a formal arbitration pleading used in LCIA proceedings to respond specifically to a Defence to Counterclaim. It is not a generic Statement of Defence or a new Counterclaim, and it explicitly limits content to material facts in response to new matters. It includes an Annexure Schedule for exhibits cross-referenced to paragraph numbers.
When should you use it?
Use this template when the Claimant has filed a Statement of Reply that includes a Statement of Defence to your Counterclaim. Use the LCIA Statement of Defence and Counterclaim instead if you are responding to the initial Request for Arbitration.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Identifies that the document is submitted pursuant to Article 15.5 of the LCIA Rules for pleading material facts only. |
| 2 | Reply to the Defence to Counterclaim | Provides a section for the Counterclaim-Claimant to address bare facts and affirmative defences raised in the previous pleading. |
| 3 | Relief Sought | Maintains the request for a specific counterclaim quantum amount and interest as originally pleaded. |
| 4 | Annexure Schedule | Lists all supporting documents relied upon by the Respondent, mapped to specific paragraph references. |
Who it's for
- a respondent in an LCIA arbitration replying to new matters in a defence to counterclaim
- legal counsel filing the final scheduled written statement in an international arbitration
- a party seeking to maintain a counterclaim quantum amount after a claimant's reply
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Respondent/Counterclaim-Claimant
Witness
Not required
Notarisation
Not required
Also needed
File within 28 days of receipt
Law it's drafted under
Governed by
LCIA Arbitration Rules (2020)
Refers to
Art. 15.3 LCIA Rules
Refers to
Art. 15.5 LCIA Rules
Refers to
Art. 15.6 LCIA Rules
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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