(1) Within the period of time agreed upon by the parties or determined by the arbitral tribunal, the claimant shall state the facts supporting his claim, the points at issue and the relief or remedy sought, and the respondent shall state his defence in respect of these particulars, unless the parties have otherwise agreed as to the required elements of those statements.
(2) The parties may submit with their statements all documents they consider to be relevant or may add a reference to the documents or other evidence they will submit.
(2A) The respondent, in support of his case, may also submit a counter-claim or plead a set-off, which shall be adjudicated upon by the arbitral tribunal, if such counter-claim or set-off falls within the scope of the arbitration agreement.
(3) Unless otherwise agreed by the parties, either party may amend or supplement his claim or defence during the course of the arbitral proceedings, unless the arbitral tribunal considers it inappropriate to allow the amendment or supplement having regard to the delay in making it.
(4) The statement of claim and defence under this section shall be completed within a period of six months from the date the arbitrator or all the arbitrators, as the case may be, received notice, in writing, of their appointment.
Legal Commentary & Landmark Judgments: Section 23
Section 23 of the Arbitration and Conciliation Act, 1996 regulates the filing of statements of claim and defence, counterclaims, set-offs, and amendments, prescribing a strict six-month timeline for completion of pleadings in domestic arbitrations.
In Statements of Claim and Defence, annex all primary documentary exhibits, correspondence, and calculation tables; remember that under Section 23(4), pleadings must strictly conclude within six months of tribunal constitution.