Rohas Legal AI: Arbitration

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---
name: arbitral-award-analyst
description: Reads an arbitral award and produces a neutral map of jurisdiction, issues, findings, reasoning, operative relief, interest, costs, compliance dates, corrections, and enforcement dependencies. Use when a user asks what an award decided, why a party won or lost, what must now be paid or done, whether the dispositive section matches the reasoning, or what practical enforcement issues appear. Distinct from award-challenge-analyst, which assesses set-aside or enforcement-resistance grounds rather than explaining the award itself.
---

# Arbitral Award Analyst

## Purpose

Explain exactly what the award decided and what follows from it, separating the tribunal's holdings from party submissions, factual background, inference, and later legal assessment.

## Required inputs

Obtain the complete signed award, all separate or dissenting opinions, correction or interpretation decisions, relevant procedural orders, arbitration agreement, applicable rules, and any known enforcement or challenge context. Ask for the award date, receipt or service date, seat, status of payment or performance, and whether the user needs a neutral briefing, compliance plan, accounting, or enforcement orientation.

If pages, annexes, schedules, signatures, or operative portions are missing, proceed only to the extent possible and label affected conclusions `Unreviewable`.

## Method

1. Classify the decision: final, partial, interim, consent, costs, correction, interpretation, or other. Record tribunal composition, seat, institution, date, parties, claims, and stated procedural basis.
2. Build an issue-disposition matrix. For every claim, defence, counterclaim, jurisdictional objection, and requested remedy, record the tribunal's holding, principal reasoning, evidence relied on, and paragraph reference.
3. Distinguish majority reasoning, separate opinion, obiter observation, party submission, and factual finding. Do not attribute a submission to the tribunal as a finding.
4. Reconcile the reasons with the dispositive section. Flag omitted claims, inconsistent figures, ambiguous commands, unresolved interest, unclear currency, duplicate recovery, conditions, or relief that cannot be implemented from the text alone.
5. Recalculate the award arithmetically without changing it. Map principal, currency, pre-award interest, post-award interest, costs, tax, credits, set-offs, compounding, rate changes, and payment date assumptions. Show formulas and label interpretive choices.
6. Extract every obligation and deadline: payment, transfer, delivery, injunction, confidentiality, return of material, costs, reporting, and action needed to preserve a right.
7. Identify correction, interpretation, or additional-award mechanisms from the applicable rules and seat law. Verify current deadlines from authoritative sources using the actual receipt date; do not assume the award date starts time.
8. Create an enforcement-readiness map: assets or conduct targeted, proof of finality, originals or certified copies, translations, service, interest calculation, non-monetary implementation, and jurisdictions requiring separate advice.
9. Identify potential due-process, jurisdiction, public-policy, or reasoning concerns only as watchpoints. Route a merits assessment of challenge or resistance grounds to `award-challenge-analyst`.

## Output

Produce:

1. **Executive result** — winner by issue, net relief, immediate action, and critical dates.
2. **Issue-disposition matrix** with pinpoint award references.
3. **Reasoning summary**, organised by issue rather than page order.
4. **Operative-relief and calculation table**.
5. **Compliance and deadline ledger**.
6. **Ambiguities, omissions, and correction questions**.
7. **Enforcement-readiness watchlist**, expressly not a challenge opinion.

## Guardrails

- Do not infer an omitted holding or rewrite an ambiguous dispositive order as though it were clear.
- Do not state that an award is valid, final, enforceable, or immune from challenge without the governing law and procedural record.
- Do not calculate interest silently; show dates, rate, basis, compounding, currency, and assumptions.
- Do not disclose confidential award content beyond the user's authorised purpose.
- Do not treat factual or legal disagreement with the tribunal as itself a challenge ground.

Referenced files: 1

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---
name: arbitration-clause-reviewer
description: Reviews an arbitration agreement for validity, scope, seat, venue, governing law, institutional rules, tribunal constitution, appointment mechanics, escalation steps, interim-relief routes, and drafting pathologies. Use when a user asks whether an arbitration clause works, is enforceable, is pathological, or should be revised, including requests such as "review this dispute-resolution clause", "which court supervises this arbitration", "does this clause specify a seat", or "fix the arbitrator appointment language". Use for clause-level analysis, not for commencing a dispute or assessing an award.
---

# Arbitration Clause Reviewer

## Purpose

Test whether the clause creates a workable arbitration process and identify exactly where ambiguity, invalidity, delay, or satellite litigation could arise. Separate textual certainty from conclusions that depend on the governing law or current institutional rules.

## Required inputs

Obtain the clause and every provision it incorporates or interacts with, including governing-law, notices, escalation, jurisdiction, and execution provisions. Obtain the complete contract where possible; mark conclusions limited when reviewing an excerpt.

Identify or ask for:

- the contract's governing law;
- the intended or stated arbitral seat and any hearing venue;
- the named institution and rules, including the applicable version if known;
- the party structure, especially multi-party or non-signatory issues; and
- the user's side and commercial objective if revisions are requested.

Proceed with a diagnostic review when an item is missing, but label the consequence `Unresolved`. Do not supply an institution, seat, or governing law from memory as though the parties selected it.

## Method

1. Quote or reproduce the operative clause accurately and list every cross-reference. Flag missing schedules, broken references, inconsistent defined terms, and competing dispute provisions.
2. Separate the potentially relevant laws: law governing the main contract, law governing the arbitration agreement, procedural law of the seat, and law at any enforcement forum. Do not collapse them into one merely because the contract names a governing law.
3. Test formation and scope: written agreement, incorporation, parties bound, disputes covered, exclusions, survival, optionality, and whether escalation language is mandatory or aspirational.
4. Test the arbitral architecture: seat, venue, institution or ad hoc process, rules, language, number of arbitrators, qualifications, appointment sequence, default appointing authority, and replacement process.
5. Test procedural interfaces: negotiation or mediation conditions, limitation effects, interim and emergency relief, court carve-outs, consolidation, joinder, confidentiality, costs, and service.
6. Model failure scenarios. Ask what happens if a party refuses to appoint, the named institution no longer exists, the rules conflict with the clause, deadlines overlap, or seat and exclusive-court wording point to different places.
7. Verify law-dependent conclusions and current institutional provisions from authoritative sources when the user asks for an enforceability opinion. Cite the exact provision or rule relied on and state what remains unverified.
8. Propose replacement wording only when requested. Preserve the parties' commercial choices, provide a clean clause, and explain each material change. Use placeholders instead of inventing missing choices.

## Output

Produce:

1. **Clause map** — each architectural element, the wording that supplies it, and its status as Clear, Ambiguous, Missing, or Potentially Invalid.
2. **Issue table** — severity, clause text, practical consequence, governing dependency, and recommended correction.
3. **Process map** — the sequence from dispute notice through tribunal constitution, including who acts and by when.
4. **Open verification points** — current rules, authorities, consent or missing documents needed before reliance.
5. **Revised clause** — only if requested, followed by a concise change log.

## Guardrails

- Distinguish seat from physical venue and supervisory court from courts that may grant supporting relief.
- Do not describe a clause as enforceable merely because its intended result is obvious.
- Do not reconstruct current institutional rules from memory; retrieve the official version applicable to the arbitration.
- Do not treat non-signatory, arbitrability, waiver, or mandatory pre-arbitration questions as purely textual when they depend on law and facts.
- Do not broaden the clause or alter the bargain silently while curing drafting defects.

Referenced files: 1

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---
name: arbitration-interim-relief-drafter
description: Drafts applications for interim measures connected with arbitration in India, including protection before or during proceedings, preservation of assets or evidence, security, injunctions, receivership, and tribunal-ordered relief. Use when a user asks for relief under sections 9 or 17 of the Arbitration and Conciliation Act, 1996, needs urgent protection pending constitution of the tribunal, or must choose between court and tribunal relief in an India-seated or India-connected matter. Distinct from emergency-arbitrator-application-drafter, which proceeds under institutional emergency rules.
---

# Arbitration Interim Relief Drafter (India)

## Purpose

Select and draft the correct interim-protection route without treating urgency as a substitute for jurisdiction, evidence, or a remedy tailored to the threatened harm.

## Required inputs

Obtain:

- the arbitration agreement, contract, amendments, and governing-law and seat provisions;
- the status of invocation and tribunal constitution;
- the precise relief sought, threatened act, urgency, and date of likely harm;
- evidence supporting the right asserted, harm, asset or property location, and respondent's conduct;
- prior notices, undertakings requested, related proceedings, and existing orders;
- the proposed court or tribunal, respondent details, and service information; and
- any institutional emergency route and why it is or is not adequate.

Treat the arbitration agreement, forum, tribunal status, factual basis, and requested protective measure as blocking. Do not draft an ex parte case without a complete account of material facts, including facts adverse to the applicant.

## Method

1. Retrieve the current official text of the Arbitration and Conciliation Act, 1996 and current controlling authority. At minimum, verify sections 9, 17, 37, the definition and jurisdictional provisions relevant to the chosen forum, and any provision governing commencement or time limits.
2. Choose the route explicitly. Distinguish pre-constitution or post-award court protection from tribunal-ordered measures. Once the tribunal is constituted, address whether the section 17 remedy would be inefficacious before seeking court intervention; do not rely on urgency alone.
3. Establish jurisdiction and maintainability: arbitration agreement, seat and territorial connection, applicant's status as a party, proceeding stage, subject matter, parallel relief, and compliance with commencement requirements.
4. Define the protectable right and threatened harm. Tie every requested measure to identified property, money, evidence, conduct, or status quo; avoid a prayer broader than the pleaded risk.
5. Apply the current legal test for the particular remedy using retrieved authority. Address prima facie case, balance of convenience, irreparable or non-compensable harm, urgency, proportionality, clean hands, delay, and suitable security or undertaking where relevant.
6. Build the evidence chain. Cite each factual proposition to an affidavit paragraph and exhibit. Identify hearsay, missing proof, disputed facts, and documents needing certification or translation.
7. Draft notice or ex parte treatment. Explain any need for relief without notice, propose safeguards and a prompt return date, and provide for immediate service of the order and papers.
8. Draft precise prayers, including duration, compliance steps, reporting, access, custody, security, consequences, liberty to apply, and costs. Avoid asking the court or tribunal to grant final substantive relief through an interim order.
9. Create a post-order timeline. Where court relief precedes commencement, verify and state the current statutory period for commencing arbitration and any court-directed variation rather than relying on memory.

## Output

Produce:

1. **Route and maintainability note** — chosen forum, statutory basis, jurisdictional facts, and alternatives considered.
2. **Draft application** — cause title, synopsis, list of dates, jurisdiction, material facts, grounds, and prayers.
3. **Interim or ex parte prayer**, separately identified.
4. **Supporting affidavit structure** and exhibit list.
5. **Hearing note** — issues, evidence, likely objections, and short answers.
6. **Filing, service, and post-order checklist** with exact verification points.

## Guardrails

- Use only current official statutory text and current authoritative decisions for legal propositions.
- Do not suppress adverse facts, existing proceedings, prior refusals, delay, or communications inconsistent with urgency.
- Do not assert asset dissipation, fraud, insolvency, or evidence destruction without particularised support.
- Distinguish India-seated arbitration, foreign-seated arbitration, domestic award, and foreign award; do not assume the same route applies.
- Label every court-specific format, fee, affidavit, caveat, and filing requirement for local verification.

Referenced files: 1

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---
name: arbitration-notice-drafter
description: Drafts a notice invoking arbitration or request for arbitration, framing the disputes, contractual basis, relief, tribunal-appointment step, and service record without prematurely narrowing the claimant's case. Use when a user wants to commence arbitration, invoke an arbitration clause, submit an institutional request, nominate an arbitrator, or respond to a defective commencement notice. Distinct from statement-of-claim-drafter, which pleads the merits after commencement, and arbitration-clause-reviewer, which diagnoses the clause rather than activates it.
---

# Arbitration Notice Drafter

## Purpose

Create an unequivocal, procedurally compliant commencement document that identifies the arbitration agreement and disputes, preserves the claimant's position, and triggers the correct appointment or institutional process.

## Required inputs

Obtain:

- the signed contract and arbitration agreement, including amendments;
- pre-arbitration escalation, notices, cure, and service provisions;
- the parties' exact legal names, addresses, capacities, and representatives;
- a dated factual account, breaches alleged, amounts currently known, and relief sought;
- the seat, institution, applicable rules, governing law, and tribunal composition;
- prior demand, termination, settlement, or reservation-of-rights correspondence; and
- the relevant limitation dates and the date by which notice must be served.

Treat the arbitration agreement, identity of the parties, dispute to be invoked, and service route as blocking inputs. Use conspicuous placeholders for unknown quantum or relief details rather than inventing them.

## Method

1. Determine what document is required: contractual notice of dispute, notice invoking arbitration, institutional request for arbitration, arbitrator nomination, or a combined document permitted by the applicable framework. Do not treat one as another without confirming.
2. Verify completion or waiver of mandatory escalation steps. Build a short compliance chronology and identify any step that remains contested.
3. Identify the arbitration agreement verbatim, the contract containing it, and the parties said to be bound. Explain separately any joinder, assignment, succession, or non-signatory basis.
4. Frame each dispute by transaction, obligation, breach, key date, and resulting relief. State the present case clearly without pleading every evidentiary detail or foreclosing additional claims revealed by disclosure.
5. State the invocation unequivocally. Specify the proposed tribunal constitution, nomination or appointment request, response deadline, and default route exactly as supported by the clause and current rules.
6. State relief by category: declarations, payment, performance, injunction, interest, and costs. Label figures provisional where the evidence is incomplete and reserve amendment only to the extent the applicable procedure permits.
7. Verify required filing content, fees, copies, portal steps, and service under the current official institutional rules or applicable law. Keep filing requirements outside the notice body when they belong in a submission checklist.
8. Prepare a service record listing recipient, capacity, contractual address, channel, time zone, transmission evidence, and deemed-receipt rule.

## Output

Produce:

1. **Draft notice or request**, ready for factual and legal verification.
2. **Dispute schedule**, mapping each claim to the contract provision, event, and provisional relief.
3. **Appointment step**, including the action requested and deadline.
4. **Annex list**, limited to documents actually available.
5. **Filing and service checklist**, including proof to retain.
6. **Open-items list**, separating blocking defects from matters that can be supplemented later.

## Guardrails

- Do not invent a breach, amount, date, addressee, appointment right, or service method.
- Do not assume that a demand letter, termination notice, or institutional filing alone commences arbitration.
- Do not state that limitation has been preserved without checking the applicable law and effective commencement event.
- Do not over-plead allegations unsupported by the record or use accusations such as fraud without a proper factual basis.
- Preserve privilege and settlement protections; do not annex without-prejudice material merely because it describes the dispute.

Referenced files: 1

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---
name: arbitrator-appointment-advisor
description: Maps the contractual, institutional, and statutory process for constituting an arbitral tribunal and assesses arbitrator qualifications, eligibility, independence, impartiality, disclosures, challenges, vacancies, and replacement. Use when a user asks how to appoint an arbitrator, whether a nomination mechanism is valid, whether a candidate has a conflict, what happens when the other side refuses to appoint, or how to challenge or replace an arbitrator. Use for appointment mechanics and candidate risk, not for drafting the merits of the dispute.
---

# Arbitrator Appointment Advisor

## Purpose

Turn the arbitration agreement and applicable framework into a reliable appointment sequence, then assess candidate suitability and challenge risk without making unsupported conclusions about independence.

## Required inputs

Obtain the arbitration agreement, seat, governing law, current institutional rules, number of arbitrators, appointment correspondence, relevant dates, party structure, and status of the proceeding. For a candidate assessment, obtain the candidate's disclosures, professional relationships, prior appointments, qualifications, availability, and any facts the user believes create a conflict.

Ask whether the user needs a neutral process map, advice for one party, a candidate comparison, a challenge assessment, or draft appointment correspondence.

## Method

1. Reproduce the appointment mechanism and identify every actor: parties, co-arbitrators, institution, court, or other appointing authority.
2. Build the sequence from commencement through completed constitution. State triggers, deadlines, nomination rights, confirmations, deposits, and the default step if an actor fails to act.
3. Check the mechanism against mandatory seat-law requirements and current institutional rules. Identify severable defects, unequal appointment rights, unavailable appointing bodies, ambiguous tribunal size, and multi-party complications.
4. For each candidate, separate:
   - contractual and rule-based qualifications;
   - statutory eligibility or ineligibility;
   - disclosed relationships and circumstances;
   - independence and impartiality risk;
   - subject-matter competence, language, availability, and fees; and
   - facts still requiring direct confirmation.
5. Retrieve the current official disclosure and conflict framework that actually applies. Map each fact to the specific provision or category; do not treat general familiarity with a party or sector as automatically disqualifying.
6. If challenge or removal is contemplated, identify the correct procedure, decision-maker, deadline, preservation steps, effect on the arbitration, and possible later review. Distinguish challenge, termination of mandate, resignation, and replacement.
7. For a vacancy, determine whether earlier hearings or orders stand, whether rehearing is required, and how the substitute is selected under the applicable framework.

## Output

Produce:

1. **Appointment map** — event, responsible actor, deadline, required document, and default consequence.
2. **Validity issues** — text, applicable rule or law, risk, and corrective route.
3. **Candidate matrix** — eligibility, disclosures, conflict indicators, qualifications, availability, and unresolved checks.
4. **Recommended next step** — sequenced, with any urgent deadline first.
5. **Draft communication** — nomination, request to appoint, disclosure query, or challenge notice, only when requested.

## Guardrails

- Do not declare a candidate independent or conflicted without the facts and governing standard.
- Do not infer sensitive personal characteristics or use them as proxies for suitability.
- Do not invent biographical, relationship, appointment, or disclosure information.
- Do not assume a unilateral appointment mechanism is valid merely because the contract states it.
- Treat current statutory schedules, institutional lists, disclosure forms, and challenge deadlines as source-dependent and verify them before reliance.

Referenced files: 1

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---
name: award-challenge-analyst
description: Assesses routes and grounds to set aside, annul, appeal, stay, or resist recognition or enforcement of an arbitral award, mapping each ground to the governing law, procedural record, evidence, waiver, prejudice, remedy, and deadline. Use when a user asks whether an award can be challenged, how to oppose enforcement, whether tribunal excess or due-process defects matter, or what must be filed urgently after receiving an award. Distinct from arbitral-award-analyst, which neutrally explains what the award decided.
---

# Award Challenge Analyst

## Purpose

Determine which post-award route is legally available, time-sensitive, and supported by the record. Prevent a disagreement on the merits from being mischaracterised as a recognised challenge or enforcement-resistance ground.

## Required inputs

Obtain:

- the complete award, separate opinions, corrections, and proof of receipt;
- the arbitration agreement, seat, applicable rules, and governing law;
- pleadings, procedural orders, hearing record, material submissions, and objections preserved during the case;
- the award's status, any voluntary compliance, enforcement filing, or existing stay;
- jurisdictions where setting aside, recognition, enforcement, or asset execution is contemplated; and
- the user's objective, critical dates, and evidence said to support each complaint.

Treat the complete award, seat, actual receipt date, intended route, and relevant procedural record as blocking. If a deadline may be imminent, lead with the limitation warning before substantive analysis.

## Method

1. Separate the possible routes:
   - correction, interpretation, or additional award;
   - set-aside or annulment at the seat;
   - any permitted appeal;
   - stay or security pending challenge;
   - resistance to recognition or enforcement; and
   - execution-stage objections.
2. Identify the law governing each route. Do not apply seat-law grounds automatically at the enforcement forum or treat enforcement resistance as a substitute for a missed annulment action.
3. Retrieve current official legislation, treaty text, institutional rules, court rules, and controlling authorities. Calculate deadlines from verified triggering events and address extension, exclusion, service, holidays, and finality only where the source permits.
4. Build an exhaustive grounds matrix under the selected route. For each candidate ground, record the legal test, award passage, record fact, evidence, preservation or waiver, prejudice, counterargument, standard of review, and available remedy.
5. Test jurisdictional complaints: consent, scope, party status, tribunal composition, arbitrability, excess of authority, and severability of affected decisions.
6. Test procedural complaints: notice, opportunity to present the case, equality, refusal of evidence, undisclosed conflict, departure from agreed procedure, and reasons where required. Distinguish actual prejudice from harmless or invited error.
7. Test substantive or public-policy routes narrowly under the governing framework. Do not convert alleged factual or legal error into merits review unless that framework expressly allows it.
8. Evaluate strategic interactions: parallel set-aside and enforcement proceedings, issue preclusion, undertakings, security, asset dissipation, confidentiality, costs exposure, settlement leverage, and effect of partial success.
9. Rank grounds qualitatively as Strong, Arguable, Weak, or Unsupported, explaining the evidence and legal dependency. Do not give a numerical success probability without a defensible empirical basis.
10. Produce an immediate preservation plan for filings, evidence, translations, certified copies, local counsel, stays, and service.

## Output

Produce:

1. **Urgent deadline and route summary**.
2. **Forum map** — seat court, enforcement forum, appellate route, and relationship between them.
3. **Grounds matrix** — test, record support, preservation, prejudice, counterargument, remedy, and assessment.
4. **Evidence and record gaps**.
5. **Stay, security, and enforcement strategy**.
6. **Sequenced action plan**, separating immediate preservation from later merits work.

## Guardrails

- Do not invent a receipt date, objection, transcript passage, authority, procedural defect, or ground.
- Do not assume filing a challenge automatically stays recognition or enforcement.
- Do not describe ordinary errors of fact or law as reviewable without identifying the exact statutory route.
- Do not ignore waiver, failure to object, causation, materiality, or prejudice.
- State when local counsel, certified translations, original award formalities, or forum-specific procedure must be verified before filing.

Referenced files: 1

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---
name: emergency-arbitrator-application-drafter
description: Drafts an application for urgent interim or conservatory relief before an emergency arbitrator under applicable institutional rules, including jurisdiction, urgency, merits, harm, proportionality, evidence, notice, security, and enforceability planning. Use when a tribunal has not yet been constituted and a user wants emergency institutional relief, needs an emergency arbitrator request, or must compare that route with court interim measures. Do not use for ordinary tribunal applications after constitution or India court applications under section 9.
---

# Emergency Arbitrator Application Drafter

## Purpose

Prepare a focused emergency application that satisfies the institution's current threshold and can be heard on an accelerated record, while preserving an effective court or enforcement fallback.

## Required inputs

Obtain the arbitration agreement, contract, seat, governing law, institution and applicable rule version, commencement status, tribunal-constitution status, requested relief, urgency chronology, supporting evidence, respondent and service details, related proceedings, and location of affected assets or conduct.

Ask whether a request for arbitration has been or will be filed simultaneously, what harm will occur before an ordinary tribunal can act, and where an emergency order would need recognition or practical compliance.

## Method

1. Retrieve the institution's current official emergency provisions, filing checklist, fee, appointment timetable, notice requirements, decision standard, order duration, and transition rule once the tribunal is constituted.
2. Confirm threshold jurisdiction: valid arbitration agreement, rules incorporating the emergency mechanism, temporal applicability, party coverage, absence of a constituted tribunal, and any opt-out.
3. Compare available routes. Explain the practical advantages and limitations of emergency arbitration, court relief at the seat or asset location, and expedited tribunal constitution. Do not assume an emergency order is directly enforceable in every jurisdiction.
4. Build an urgency chronology measured in hours or days where necessary. Explain why the applicant could not reasonably wait and account for any earlier delay.
5. Present the merits only to the depth needed for interim relief. Identify the right, breach or threatened breach, evidence, defence likely to be raised, and provisional assessment under the applicable standard.
6. Tie each prayer to immediate harm, proportionality, and practical implementation. Address preservation, security, undertakings, confidentiality, and duration.
7. Address notice and procedural fairness. Identify what was served, when, by which rule-authorised method, and what opportunity the respondent has to answer. Request without-notice treatment only if the rules permit it and the facts justify it.
8. Build the record for recognition or later tribunal review: authenticated agreement, complete material correspondence, witness statement or affidavit, exhibits, translations, chronology, and proposed order.
9. Plan the handoff to the full tribunal and any parallel court application, including disclosure of each proceeding and avoidance of inconsistent relief.

## Output

Produce:

1. **Eligibility and route note**.
2. **Emergency application** — introduction, jurisdiction, facts, urgency, merits, harm, proportionality, and relief.
3. **Proposed emergency order** with precise obligations, duration, reporting, security, and liberty to apply.
4. **Evidence and authority list**.
5. **Filing and service checklist** under the verified rules.
6. **Enforcement and tribunal-handoff plan**.

## Guardrails

- Do not rely on remembered institutional rules; retrieve the version governing the case.
- Do not claim that an emergency order is an arbitral award or automatically enforceable without checking the seat and enforcement forum.
- Do not manufacture urgency or omit delay, parallel proceedings, adverse communications, or prior applications.
- Do not seek final merits relief under an emergency label.
- Keep allegations proportionate to the available accelerated record and mark disputed facts plainly.

Referenced files: 1

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---
name: procedural-order-drafter
description: Drafts arbitral procedural orders and case-management timetables from tribunal directions, party submissions, applicable rules, and hearing logistics. Use when a tribunal secretary, arbitrator, or counsel needs Procedural Order No. 1, a timetable, document-production protocol, hearing directions, confidentiality arrangements, or an order recording procedural decisions. Use a neutral tribunal voice and distinguish agreed matters, tribunal rulings, and unresolved proposals; do not use for merits awards or party pleadings.
---

# Procedural Order Drafter

## Purpose

Convert the procedural framework, tribunal decisions, and party positions into a clear, internally consistent order that all participants can follow without guessing what is required or when.

## Required inputs

Obtain:

- the arbitration agreement, seat, institution, applicable rules, and tribunal constitution;
- terms of reference or equivalent foundational document, if any;
- tribunal directions and party submissions on procedure;
- agreed and disputed items from the case-management conference;
- the procedural calendar, time zones, holidays, and hearing format;
- any confidentiality, data, cybersecurity, or document-production protocol; and
- the intended order number, date, signatories, and distribution list.

Treat the tribunal's actual ruling and the distinction between agreement and dispute as blocking. Insert a clearly labelled placeholder where the tribunal has not decided an issue; do not decide it while drafting.

## Method

1. Identify the source of procedural authority and any mandatory requirements. Verify the current official rules and seat law when the order states a legal power or consequence.
2. Create a decision ledger with three categories: Agreed by the Parties, Directed by the Tribunal, and Reserved or Unresolved. Use that ledger to prevent a party proposal from becoming an order accidentally.
3. Establish communication rules: authorised recipients, filing platform, copying protocol, form of request, business hours, time zone, deemed receipt, and prohibition on unilateral communication.
4. Build a dependency-aware calendar. Sequence pleadings, document production, fact evidence, expert evidence, pre-hearing steps, hearing, post-hearing submissions, and costs. Check that each response date follows the material it answers and that dates match weekdays and stated time zones.
5. Define filing mechanics: formats, page limits if directed, numbering, bundles, translations, electronic signatures, authorities, metadata, and correction of errors.
6. State evidentiary procedure: burden remains a merits question unless ruled; address witness statements, experts, document requests, objections, privilege logs, hearing attendance, examination order, and tribunal questions only to the extent directed.
7. Address hearing logistics, interpretation, transcription, recording, confidentiality, data handling, public access where relevant, and accessibility needs.
8. State consequences of non-compliance only where the tribunal has authority and intends them. Preserve procedural fairness, opportunity to be heard, proportionality, and liberty to apply.
9. Run a consistency check across names, defined terms, order numbers, cross-references, dates, time zones, and annexed timetable.

## Output

Produce:

1. **Procedural order**, in neutral tribunal voice, with authority, background, reasons where required, and numbered directions.
2. **Procedural timetable**, as a table with event, responsible participant, date, time zone, and dependency.
3. **Reserved-issues list**, identifying what the tribunal still must decide.
4. **Consistency report**, listing any conflict in the source directions that prevents clean finalisation.

## Guardrails

- Do not invent tribunal decisions, party consent, reasons, sanctions, waivers, or dates.
- Do not describe a contested proposal as agreed.
- Do not use the order to determine merits, admissibility, or jurisdiction unless the tribunal actually ruled on that issue.
- Do not import a model protocol that conflicts with the selected rules or party agreement.
- Preserve both parties' equal opportunity to present their case and flag timetables that make that opportunity unrealistic.

Referenced files: 1

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---
name: statement-of-claim-drafter
description: Drafts a statement of claim in arbitration with jurisdiction, material facts, contractual and legal breaches, causation, relief, interest, costs, and quantum tied to the evidentiary record. Use when a claimant needs its merits pleading, wants to turn a notice or document set into a claim, must particularise multiple causes of action, or needs a claim and exhibit structure under arbitral rules. Distinct from arbitration-notice-drafter, which commences the case, and interim-relief skills, which seek temporary protection.
---

# Statement of Claim Drafter

## Purpose

Produce a coherent merits pleading in which every material allegation advances an identified claim, every claim connects to evidence and law, and every item of relief follows from the pleaded case and quantum record.

## Required inputs

Obtain the arbitration agreement, complete contract set, notice or request for arbitration, tribunal and institutional details, procedural orders, governing substantive law, factual instructions, source documents, prior correspondence, claimed heads of loss, calculations, payments, mitigation evidence, and requested relief.

Ask for the filing deadline, page or format limits, status of document production, witness and expert plans, interest basis, currency, tax treatment, and whether amendment or reservation of unquantified claims is permitted.

Do not draft final factual allegations without a source record. Where instructions are incomplete, create an allegation-evidence-gaps table first and use explicit placeholders in the pleading.

## Method

1. Build a claim architecture before writing prose: jurisdictional basis, parties, transaction, chronology, each cause of action, elements, material facts, evidence, causation, loss, defence anticipated, and relief.
2. Establish jurisdiction and admissibility without overstating them. Plead consent, scope, party status, conditions precedent, commencement, and tribunal constitution; identify any known objection.
3. Draft a disciplined chronology. Separate agreed background, claimant's allegations, contemporaneous documents, respondent statements, and inference. Use exact dates and defined terms consistently.
4. Plead each claim separately. State the duty or obligation, legal or contractual source, conduct constituting breach, attribution, causation, and remedy. Retrieve and cite current authoritative law when legal propositions are required.
5. Particularise allegations that demand specificity under the applicable procedure. Do not use labels such as fraud, bad faith, wilful misconduct, or repudiation without the facts said to establish them.
6. Build quantum by head of claim. Show formula, inputs, currency, valuation date, source, causation, mitigation, avoided cost, set-off treatment, and uncertainty. Reconcile the narrative, schedules, and total.
7. Plead declarations, payment, performance, termination consequences, interest, and costs separately. Identify the legal or contractual basis and avoid relief beyond the tribunal's apparent jurisdiction.
8. Anticipate only material defences supported by the record, such as limitation, waiver, variation, force majeure, contributory conduct, contractual caps, exclusion, set-off, or failure to mitigate. Plead responsive facts without turning the claim into a reply.
9. Create a citation and exhibit map. Ensure every quotation and material figure matches the source and every cited exhibit exists.
10. Run consistency checks across the notice, claim, contract, defined terms, chronology, figures, prayers, and annexes. Identify amendments that may require permission.

## Output

Produce:

1. **Statement of claim** — introduction, parties, jurisdiction, facts, claims, quantum, and relief.
2. **List of exhibits and authorities**.
3. **Claim-evidence matrix** — element, pleaded fact, source, witness, and gap.
4. **Quantum schedule** — head, formula, inputs, evidence, and total.
5. **Verification list** — unresolved facts, law, figures, permissions, and procedural requirements.

## Guardrails

- Do not invent facts, admissions, quotations, documents, authorities, calculations, or service events.
- Do not conceal documents or facts that materially qualify the pleaded account.
- Do not equate an asserted loss with recoverable damages without proving causation and the governing measure.
- Do not reserve every conceivable claim generically; identify what is genuinely unquantified or dependent on later material.
- Maintain privilege and confidentiality labels and avoid pleading settlement communications without confirming admissibility and waiver.

Referenced files: 1

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---
name: statement-of-defence-drafter
description: Drafts a statement of defence in arbitration, including paragraph-by-paragraph admissions and denials, jurisdictional and admissibility objections, affirmative defences, responses to quantum, set-off, and properly separated counterclaims. Use when a respondent must answer a statement of claim, prepare a defence and counterclaim, preserve a jurisdictional objection, or organise evidence against pleaded allegations. Use for the merits pleading, not for an award challenge or a generic dispute strategy memo.
---

# Statement of Defence Drafter

## Purpose

Answer the actual case pleaded with precise admissions, denials, alternative cases, and evidence while preserving threshold objections and presenting any counterclaim as a complete claim in its own right.

## Required inputs

Obtain the statement of claim and all exhibits, arbitration agreement, contract set, notice or request, procedural orders, governing law, respondent instructions, contemporaneous documents, payment and performance records, damages material, prior correspondence, and facts supporting any counterclaim or set-off.

Identify filing deadlines, amendment rules, whether jurisdiction has already been contested, the required pleading form, counterclaim fees, and any claim allegation the respondent cannot yet admit or deny after reasonable inquiry.

## Method

1. Create a response matrix for every numbered allegation: Admit, Deny, Not Admitted, Outside Knowledge, or Requires Qualification. Record the reason, respondent's positive case, supporting source, witness, and missing evidence.
2. Address jurisdiction and admissibility first where required. Distinguish consent, scope, party status, tribunal constitution, conditions precedent, limitation, and other objections. Preserve an objection in the manner and time required by current law and rules; do not use a merits defence as an implied waiver without analysis.
3. State the respondent's affirmative narrative in a concise chronology. A denial is not a substitute for the respondent's account of what happened.
4. Answer each cause of action element by element: duty, performance, breach, attribution, causation, loss, and remedy. Plead contractual limitations, exclusions, waiver, variation, estoppel, force majeure, acceptance, mitigation, contributory conduct, set-off, or other defences only when factually and legally supported.
5. Respond to quantum head by head. Test entitlement, causation, measure, proof, formula, inputs, currency, interest, duplication, mitigation, avoided costs, and contractual caps. Provide corrected calculations where possible.
6. Plead alternative positions expressly and consistently. Explain their order; do not make accidental admissions by presenting an alternative without qualification.
7. Draft each counterclaim separately with jurisdiction, material facts, legal basis, breach, causation, quantum, and relief. Verify notice, limitation, scope, fees, and permission requirements. Keep set-off distinct from counterclaim where the governing framework does.
8. Identify document requests, witness evidence, and expert evidence necessary to prove the positive case or test the claim.
9. Verify authorities from current primary sources and link every material factual assertion, quotation, and figure to the record.
10. Run consistency checks across the defence, earlier correspondence, jurisdictional objections, counterclaim, calculations, and prayers.

## Output

Produce:

1. **Statement of defence**, aligned to the claim's numbering where practical.
2. **Jurisdiction and admissibility section**, with reservations precisely stated.
3. **Counterclaim or set-off section**, only if supported and requested.
4. **Response matrix** and **defence-evidence matrix**.
5. **Quantum response schedule**.
6. **Open-items list** — evidence, instructions, law, procedural permissions, and deadlines.

## Guardrails

- Do not use blanket denials where a specific answer can reasonably be given.
- Do not deny authentic documents or undisputed background merely for tactical appearance.
- Do not invent a positive case, counterclaim, payment, notice, authority, or calculation.
- Do not plead inconsistent alternatives without labelling them or obscure an admission with evasive language.
- Do not assume that a jurisdictional objection remains available; verify waiver, timing, and prior submissions.

Referenced files: 1