Under Section 23 of the Arbitration and Conciliation Act, 1996, the claimant must state the facts supporting its claim, the points at issue and the relief or remedy sought, within the period agreed by the parties or fixed by the tribunal. The statement of claim is the claimant's first and most important opportunity to frame the dispute.
A clear structure helps. Begin with the parties and the arbitration agreement, including how the tribunal was constituted. Then set out the contract and relevant terms. Follow with a chronological statement of facts, cross-referenced to documents. Then identify the issues and the legal basis for each claim. Finally, quantify each head of claim separately and state the relief sought, including interest and costs.
Quantification deserves care. Each head of claim should be separately calculated, with the method explained and supporting documents referenced. Tribunals are reluctant to award lump sums that are not properly broken down.
Attach the key documents — the contract, key correspondence, invoices, notices — to the statement of claim itself. Under Section 23(3), parties may submit documents they consider relevant with their statements, and doing so early makes the case easier to follow.
Finally, remember that amendments are possible but not unlimited. The tribunal may refuse amendments made late or that would prejudice the other side, so it is worth getting the claim right at the outset.