File a response within 15 days of receiving the claim.

State the precise damage sought by the party and the method of calculation of such damage.

Don't make criminal allegations as such cases can be decided through Arbitration or Mediation.

Exhibits containing the evidence that will be submitted for proving substantive issues including issues of liability, damage, trading activities and timelines should be annexed to the statement of claim.

Instead of attaching detailed documents for instance monthly statement and tax returns, it is more beneficial to attach a clear and concise summary of these documents.

Similarily for documents containing details of financial transactions, accounts and bills a chart or table explaining particulars of such documents should be attached. Additionally, any verification of these documents done by the experts in that field should also be attached.

Mention the remedial steps, if any, taken by you to mitigate the dispute.

Don't include your personal views and opinions.

This however does not mean that the party should adopt a ‘boilerplate template’ without customizing it to befit the facts and circumstances of the dispute.

The respondent should also point out any discrepancies in the facts put forth by the claimant.

It should include counterclaims or additional issues raised by the respondents.

The respondents should also include objections to the relief claimed and additional method for calculation of damages.

Respondents should bring into the light any financial hardship faced by them which could not have been foreseen at the time of making the contract,

Additionally, they may also make any comments, if required, regarding the appointment, choice of arbitrators, law applicable to procedural and substantive portion of the disputes, the seat and language of the arbitral proceedings.

Respondents should also annex relevant documents concerning counterclaims, response to claim or evidence to be presented.

While responding to the allegations made in the ‘statement of claims’ the respondents should refer to associated paragraph numbers for the sake of clarity.

Article 5 of ICC Rules, Article 2 of LCIA Rules, Article 4 of SIAC Rules , Article 5 of HKIAC Rules and Article 5 of UNCITRAL Rules lays down elements for statement of defence or response to the Notice of arbitration.