Drafting Statement of Claims with the help of AI – Part 2 

This article forms Part 2 of our practical guide on drafting statements of claim and defence in arbitration under Indian law. Building upon the background discussed in Part 1. This part demonstrates how to effectively prepare a statement of claim using AI tools. The article highlights what AI can and cannot do, offers practical tips to avoid common errors, and reinforces the importance of human oversight in legal drafting.

This is the Learning with AI series, where we figure out how to get legal work done faster, smarter, and maybe even a little easier, with the help of AI.

From drafting and research to reviewing contracts or keeping up with the latest case law, we will break down how to actually use AI in your day-to-day legal work; no jargon, no hype, just useful stuff you can start trying right away.  Check out other ones here. 

Introduction

Welcome back to the second part of our guide on drafting statements of claim and defence in arbitration matters under Indian law.

If you remember, in the first part of this series, we spent time with Mr. Vasu Raghavan, the director of Aether Tech Solutions Pvt. Ltd., who came to us completely confused and worried. His company had entered into a Vendor Supply Agreement with Neeraj Industrial Components Pvt. Ltd. for the supply of smart home electronic components, and everything seemed perfect at the start.

But things soon began to unravel.

We saw how Vasu’s business faced trouble because of late deliveries, defective products, and endless emails that went unanswered. Eventually, when Aether Tech withheld the final payment because of the poor quality goods received, the supplier, to everyone’s surprise, sent legal notices demanding the balance payment. The dispute turned serious, and Vasu approached you, his lawyer, to take the matter to arbitration as per the agreement.

In Part 1, we carefully understood:

• What is a statement of claim and a statement of defence?
• Why are these documents the backbone of any arbitration?
• The importance of clarity, completeness, and proper framing while drafting them.

We also saw how AI tools like ChatGPT, Claude can help us create these documents in a structured and professional way. But we agreed on one important truth: AI is only as good as the information we give it.

Now, in this second part, we will go a step further.

We are going to see exactly how to draft a statement of claim, the document that will set the tone for Vasu’s arbitration using AI. This is more than just theory. You and I will walk through the sections of the claim, look at the details, and see how the AI drafted a clean, clear statement because we gave it full, specific, and correct information.

And along the way, we will remind ourselves:

If you forget to give a fact, AI will forget to include it. If you are detailed, AI will be detailed too.

So let us start and see how Vasu’s story comes alive in the form of a strong, well-drafted statement of claim that can confidently be placed before the arbitral tribunal.

Structure of the Statement of Claim

Before we get to drafting, let us quickly look at the structure of the claim. 

Section one: The heading

Now, this may sound simple, but even the heading of a statement of claim needs to be carefully structured. AI tools like ChatGPT can easily format the heading properly if you are clear with your details.

Section two: Parties and jurisdiction

This part is crucial. The AI clearly listed the claimant and the respondent because we gave full details: names, designations, registered addresses, contact numbers, and emails. Without these, AI would either leave placeholders (like “[Insert Claimant Name]”) or make assumptions you would not want.

What else can you do? You could also mention the nature of each party, for example, if one is a vendor and the other a service recipient. AI can add these descriptors if you specify them.

Section three: Background facts

Here is where you start telling your client’s story.

Thanks to the complete timeline and the details you gave (like the date of the agreement, payment terms, delivery phases, and failure incidents), the AI could draft a structured and understandable background.

However, and this is important if you miss giving these facts, the AI may either skip essential events or summarise wrongly. For instance, if you had not told them about the 37% defect rate in QA testing, this crucial point would not have appeared.

What you could add here: Sometimes, lawyers forget to mention earlier disputes or prior contracts. You can tell the AI about these, and it will include them in this section.

Section four: Cause of action

The AI generated a solid cause of action here because you provided the breaches, delay, defects, ignored quality standards, and wrongful demand for full payment.

But you can take it further. For example:

• Tell the AI if you want to include legal provisions 
• Mention if you want to claim damages for anticipatory breach.
• If the respondent acted fraudulently, the AI will frame this legally.

If you leave this unsaid, AI cannot guess it.

Section five: Relief sought

Here is where clarity really matters. You gave the refund amount, extra costs claimed, and the interest you wanted and the AI neatly included this.

But what if you wanted an injunction? Or specific performance? Or even damages for loss of reputation? The AI will only include these if you spell them out.

A tip: AI can even help you calculate interest if you tell it the rate and period. You need not do it separately.

What you could add here: You can instruct the AI to include costs of arbitration, legal fees, and declarations; the AI will not assume this unless you say so.

Section six: Statement of truth

The AI automatically included the standard Indian law “Statement of Truth” format, thanks to the clear instruction you gave to follow Indian arbitration practice.

But if you forget to tell it to add this, or if you do not specify which jurisdiction’s style you want (for example, Delhi or Mumbai), it may skip or generalise this section.

A tip here: You can also instruct AI to add the claimant’s authorised signatory name, designation, and place; it will happily do this.

Section seven: Annexures

You gave a perfect list of documents, and the AI listed them properly as Annexures A to I.

But remember, AI cannot create these documents. It can only list what you tell it to. So if you forget to mention the QA report or the invoices, they will not appear here.

A tip here: You can ask AI to describe briefly what each annexure is, and it will include one-liner descriptions for each, making your claim more professional.

Drafting with AI

It is important to give clear prompts to whichever AI tool you are using. The result fully relies on it. I used Claude; you can choose any AI of your liking. 

PROMPT 1 – 

Act as a lawyer and draft a statement of claim (arbitration as per Indian laws). I will provide you with details. The following is the structure that has to be followed. 

1. Heading: 
2. Parties and Jurisdiction: 
3. Background Facts: 
4. Cause of Action: 
5. Relief Sought:
6. Statement of Truth: 
7. Annexures:

The reply – 

I understand you’d like me to draft a statement of claim for arbitration under Indian law following the structure you’ve provided. I’m ready to help you prepare this legal document.

Please provide me with the following details so I can draft a comprehensive statement of claim:

Party Information:

• Name and details of the claimant(s)
• Name and details of the respondent(s)
• Registered addresses and contact details

Dispute Details:

• Nature of the contract/agreement
• Date of the agreement
• Key terms relevant to the dispute
• Arbitration clause details
• Specific breach or dispute that occurred
• Timeline of events
• Communications exchanged between parties

Financial/Relief Information:

• Amount claimed (if monetary)
• Other specific reliefs sought
• Interest calculations if applicable

Supporting Documents:

• List of documents you want to reference as annexures

Arbitration Details:

• Seat of arbitration (if specified in agreement)
• Applicable arbitration rules (if any)
• Number of arbitrators

Once you provide these details, I’ll draft a comprehensive statement of claim following the seven-part structure you’ve outlined, ensuring compliance with the Arbitration and Conciliation Act and relevant Indian legal principles.

Please share the specific facts and details of your case.

---

Now, you must fill in the details. Be clear and provide it with all the information it has asked for. You can also add information which is outside of this as well. My second prompt is going to be only the information. Since you have already asked what you need, it will provide you with it without any further direction. 

PROMPT 2 – 

1. Party Information

a. Claimant

Name: Aether Tech Solutions Pvt. Ltd. Director: Mr. Vasu Raghavan Registered Address: No. 42, 3rd Cross, Koramangala Industrial Layout, Bengaluru – 560034, Karnataka, India Contact: +91 98450 12345 | [email protected]

b. Respondent

Name: Neeraj Industrial Components Pvt. Ltd. Director: Mr. Neeraj Malhotra Registered Address: Plot No. 7, Sector 18, Udyog Vihar, Gurugram – 122015, Haryana, India Contact: +91 98760 65432 | [email protected]

2. Dispute Details

a. Nature of the Contract/Agreement

Vendor Supply Agreement for the manufacturing and supply of smart home electronic components, including PCBs and semi-assembled units.

b. Date of Agreement

March 1, 2023

3. Key Terms Relevant to the Dispute

a. Total contract value: ₹2.4 crore

Clause 4.1 – The total contract price shall be ₹2.4 Crores, payable in the following manner:

• Advance Payment: Thirty per cent (30%) of the total contract value, i.e., ₹72,00,000, shall be paid upon execution of this Agreement.
  
• Interim Payment: Forty per cent (40%) of the total contract value, i.e., ₹96,00,000, shall be paid upon successful completion and delivery of Phase 2 deliverables, as specified in Clause 5.2 below.
  
• Final Payment: The remaining thirty per cent (30%), i.e., ₹72,00,000, shall be paid upon final acceptance of the Phase 3 deliverables.

b. Project Deliverables and Timeline

Clause 5.1 – The Deliverables under this Agreement shall be completed and delivered in the following three phases:

• Phase 1 – Prototype Delivery: The Supplier shall deliver the working prototype on or before April 15, 2023.
• Phase 2 – First Production Batch: The Supplier shall deliver the first production batch of goods, in the quantity and specifications agreed, on or before June 30, 2023.
• Phase 3 – Final Bulk Delivery: The Supplier shall complete and deliver the final bulk order on or before September 15, 2023.

Clause 5.2 – All deliverables shall conform to the quality standards and technical specifications set forth in Schedule B of this Agreement.

c. Quality Standards and Inspection

Clause 6.1 – The Buyer shall have the right to inspect the deliverables upon delivery. The deliverables must conform to the specifications, tolerances, and performance benchmarks as defined in Schedule B.

Clause 6.2 – In the event any goods are found to be defective, non-conforming, or otherwise not in compliance with the agreed specifications, the Buyer shall have the right to reject such goods and notify the Supplier in writing.

Clause 6.3 – The Supplier shall, at its sole cost and expense, replace any rejected goods within 15 (fifteen) days of receipt of the rejection notice

d. Liquidated Damages

Clause 7.1 – Time is of the essence in this Agreement. In the event of delay in delivery of any phase beyond the stipulated timelines under Clause 5.1, the Supplier shall be liable to pay liquidated damages to the Buyer at the rate of 0.5% (zero point five percent) of the total contract value per week of delay, subject to a maximum cap of 5% (five percent) of the total contract value.

Clause 7.2 – The Parties agree that the aforesaid liquidated damages are a genuine pre-estimate of the losses likely to be suffered by the Buyer and shall not be construed as a penalty.

e. Right to Reject

Clause 8.1 – The Buyer reserves the right to reject any goods which do not meet the quality and performance requirements as per Schedule B.

Clause 8.2 – Such rejection shall be communicated in writing within 10 (ten) business days of delivery, failing which the goods shall be deemed accepted.

4. Arbitration Clause Details

a. Clause 12 of the agreement provides:

“All disputes or differences arising out of or in connection with this Agreement shall be resolved through arbitration in accordance with the Arbitration and Conciliation Act, 1996. The seat of arbitration shall be Bengaluru. The arbitration shall be conducted by a sole arbitrator mutually appointed by the parties.”

The arbitration shall be conducted in accordance with the provisions of the Arbitration and Conciliation Act, 1996 (as amended), by a sole arbitrator mutually appointed by the Parties.

Clause 9.3 – The seat and venue of arbitration shall be Bengaluru, and the arbitration proceedings shall be conducted in the English language.

Clause 9.4 – The award rendered by the arbitrator shall be final and binding on the Parties.

b. Specific Breach or Dispute that Occurred

Repeated delays in delivery (Prototype and Phase 2)

Defective goods with a 37% failure rate in QA testing

Ignoring quality benchmarks and communication

Demand for full payment despite failure to meet contractual obligations

c. Timeline of Events

March 1, 2023 – Agreement executed

April 15, 2023 – Prototype deadline missed

May 5, 2023 – Faulty prototype delivered

June 30, 2023 – Phase 2 batch due

July 22, 2023 – Late delivery of Phase 2 batch

August 5, 2023 – QA report showing 37% defective units

August 8 – 25, 2023 – Multiple emails raising performance concerns

October 20, 2023 – Respondent demands final payment

November 10, 2023 – Notice of Dispute issued by Claimant

December 2023 & February 2024 – Legal notices received from the Respondent

March 2024 – Claimant engages an alternate vendor

5. Communications Exchanged

It is pertinent to note that the present dispute did not arise out of a single isolated incident but is the result of repeated lapses, delays, and quality issues on the part of the Respondent, as documented in the correspondence exchanged between the Parties over several months.

The Claimant had, from time to time, followed up on the agreed timelines and raised concerns regarding delays and defects. Key instances include:

• Email dated April 17, 2023: The Respondent informed of a delay in Phase 2 delivery, citing operational difficulties.
• Email dated May 6, 2023: The Claimant reported quality assurance failure in the prototype and sought urgent rectification.
• Emails dated August 8, 14, and 25, 2023: The Claimant issued repeated defect reports and notices of non-performance, specifically pointing out quality shortfalls in the Phase 2 and Phase 3 batches and requesting immediate corrective action.

Despite these repeated notices and requests, the Respondent either deferred the issue on one pretext or the other or failed to take timely corrective steps. The cumulative effect of these persistent defaults has led to the current dispute.

Legal notices from Respondent: December 15, 2023, and February 7, 2024

Notice of Dispute from Claimant: November 10, 2023

6. Financial / Relief Information

a. Amount Claimed

• Refund of ₹96 lakhs paid toward defective goods
• Additional claim of ₹28 lakhs for rectification and repurchase costs from the alternate vendor
• Total claim amount: ₹1.24 crore

b. Interest Calculations

• Interest @12% p.a. from date of breach (August 5, 2023) on ₹96 lakhs
• Total interest as of June 2025: approximately ₹23 lakhs

7. Supporting Documents (Annexures)

AnnexureDocumentACopy of executed Vendor Agreement (March 1, 2023)BDelivery schedule and Payment breakdownCQA Failure Report dated August 5, 2023DEmail correspondence (April to August 2023)ENotice of Dispute (November 10, 2023)FRespondent’s legal notices (Dec 2023 & Feb 2024)GProcurement invoices from alternate vendorHPayment records for disputed amountIInterest calculation chart

8. Arbitration Details

Seat of Arbitration: Bengaluru, Karnataka

Applicable Arbitration Rules: Arbitration and Conciliation Act, 1996 (India)

Number of Arbitrators: One (sole arbitrator to be mutually appointed)

Language: English

---

Here is the draft provided by Claude. 

Changes to be made

While the draft Statement of Claim generated by Claude provides a strong foundation, certain manual edits are necessary to bring it in line with standard arbitration practice and improve its legal clarity and structural coherence.

Below are the key changes to be implemented:

Structural simplification

The current draft includes unnecessary subdivisions, headings, and segmentation that are more appropriate in written submissions or court pleadings. However, in arbitration, a Statement of Claim is typically structured in a straightforward, narrative format. It should read as a continuous legal and factual story rather than as a fragmented document.

Accordingly, I removed excessive headings or numbered bifurcations and presented the facts chronologically and cohesively.

Revised language in the prayer clause

The language of the prayer in the current draft requires modification to align with best practices. The prayer must be legally precise, avoiding vague language. 

Elaboration of facts and laws

AI will not give you the most comprehensive draft. You can use it as your base and build up on it. This includes referring to clauses, adding more details that AI might have missed out on, and maintaining the flow and chronological order of events. These are a few things that AI might not do perfectly, and you know your case better than Claude, so you will need to apply that knowledge and your expertise as a lawyer. 

So it went from this:

The Claimant respectfully seeks the following reliefs from this Honourable Arbitral Tribunal…

To this:

Therefore, given the aforesaid facts and circumstances, it is most respectfully prayed that this Hon’ble Arbitral Tribunal may graciously be pleased to ….

These refinements will ensure that the Statement of Claim is clear, persuasive, and procedurally sound, thereby enhancing its effectiveness before the arbitral tribunal.

Below is the final draft with the manual changes made –

BEFORE THE LD. SOLE ARBITRATOR
JACOB JOSE

BETWEEN

AETHER TECH SOLUTIONS PVT. LTD.

AND

NEERAJ INDUSTRIAL COMPONENTS PVT. LTD.

STATEMENT OF CLAIM

Most respectfully showeth:

1. That the Claimant, Aether Tech Solutions Pvt. Ltd., is a private limited company duly incorporated under the Companies Act, 2013, having its registered office at No. 42, 3rd Cross, Koramangala Industrial Layout, Bengaluru – 560034, Karnataka, India. The Claimant is engaged in the business of smart home technology solutions and electronic device manufacturing.
2. That the Respondent, Neeraj Industrial Components Pvt. Ltd., is a private limited company duly incorporated under the Companies Act, 2013, having its registered office at Plot No. 7, Sector 18, Udyog Vihar, Gurugram – 122015, Haryana, India. The Respondent is engaged in the business of manufacturing electronic components, PCBs, and semi-assembled units.
3. That the Claimant is a technology company specialising in the design and development of smart home electronic solutions and related components, and the Respondent is a manufacturing entity engaged in the production of industrial components, printed circuit boards (PCBs), and semi-assembled electronic units.
4. In early 2023, the Claimant approached the Respondent to fulfil its requirement for high-quality smart home electronic components, including PCBs and semi-assembled units, to meet the Claimant’s project timelines for a smart home automation product launch. Following negotiations, the parties executed the Vendor Supply Agreement (“Agreement”) on March 1, 2023, wherein the Respondent, as the vendor, agreed to manufacture and supply the specified components for a total contract value of ₹2.4 crores. The Claimant, as the purchaser, relied on the Respondent’s expertise and assurances of timely delivery and quality compliance.
5. That as per Clause 4.1 of the Agreement, the payment terms were structured as follows: an advance payment of 30% (₹72,00,000) upon execution of the Agreement on March 1, 2023, an interim payment of 40% (₹96,00,000) upon successful completion and delivery of Phase 2 deliverables, and a final payment of 30% (₹72,00,000) upon final acceptance of Phase 3 deliverables. A copy of the delivery schedule and payment breakdown as per the Agreement is hereto annexed and marked as Exhibit B.
6. That pursuant to Clause 5.1 of the Agreement, the deliverables were to be completed in three phases: Phase 1 required the delivery of prototypes by April 15, 2023; Phase 2 required the delivery of the first production batch by June 30, 2023; and Phase 3 required the final bulk delivery by September 15, 2023.
7. The Claimant fulfilled its contractual obligations by making the advance payment of ₹72,00,000 on March 2, 2023, and the interim payment of ₹96,00,000 on July 25, 2023, totalling ₹1,68,00,000, as evidenced by payment records. The interim payment was made in good faith, expecting rectification of defects. Bank transaction receipts evidencing payments of ₹72,00,000 on March 2, 2023, and ₹96,00,000 on July 25, 2023, are hereto annexed and marked as Exhibit-C.
8. That the Respondent, however, materially breached the Agreement in the following manner: (i) failed to deliver the prototype by April 15, 2023, as required under Clause 5.1; (ii) delivered a faulty prototype on May 5, 2023, which did not meet the technical specifications outlined in Schedule B of the Agreement; (iii) delayed the delivery of the Phase 2 production batch until July 22, 2023, 22 days beyond the stipulated deadline; and (iv) supplied goods with a 37% failure rate in quality assurance testing, as evidenced by the Quality Assurance Failure Report dated August 5, 2023, which failed to comply with the stringent quality standards set forth in Schedule B, including a maximum defect rate of 2%, compliance with IPC-A-610 Class 2 standards, and adherence to the Claimant’s proprietary technical specifications for smart home components. A copy of the Quality Assurance Failure Report dated August 5, 2023, is hereto annexed and marked as Exhibit D.
9. That Schedule B of the Agreement specified stringent quality standards, including a maximum defect rate of 2% for printed circuit boards (PCBs) and semi-assembled electronic units, compliance with IPC-A-610 Class 2 standards for electronic assemblies, and adherence to the Claimant’s proprietary technical specifications for smart home components, including precise soldering requirements, circuit functionality, and compatibility with designated software protocols.
10. That the Claimant promptly notified the Respondent of these breaches through written communications, including a detailed email dated May 10, 2023, highlighting the faulty prototype and urging corrective action. Similar emails were sent on June 15, 2023, and July 30, 2023, addressing delays and quality issues. Copies of email correspondence between the parties from April to August 2023 are hereto annexed and marked as Exhibit E. The Respondent acknowledged the issues in a reply dated June 20, 2023, promising rectification but failed to take effective measures.
11. That due to the Respondent’s failure to deliver conforming goods and adhere to the agreed timelines, the Claimant was compelled to engage an alternate vendor in March 2024 to procure conforming goods, incurring additional costs of ₹28,00,000. A copy of procurement invoices from the alternate vendor is hereto annexed and marked as Exhibit F.
12. That the Respondent’s breaches constitute a fundamental violation of the Agreement, particularly Clauses 5.1 (delivery timelines), 5.2 (quality standards), and 6.3 (replacement of rejected goods within 15 days). The Respondent’s failure to replace defective goods or provide conforming products further exacerbated the Claimant’s losses.
13. That on November 10, 2023, the Claimant issued an invocation notice to the Respondent, outlining the breaches and seeking an amicable resolution. A copy of the invocation notice dated November 10, 2023, is hereto annexed and marked as Exhibit-G. The Respondent, instead of addressing the issues, issued legal notices dated December 15, 2023, and February 7, 2024, demanding the final payment of ₹72,00,000 despite its non-performance and delivery of non-conforming goods. Copies of the legal notices from the Respondent are hereto annexed and marked as Exhibit H.
14. That the Claimant protested the Respondent’s unjust demand through a reply dated December 20, 2023, reiterating the breaches and rejecting the claim for final payment due to non-fulfilment of the Agreement. On February 15, 2024, the Claimant issued a notice invoking arbitration under Clause 12 of the Agreement, seeking resolution through this Hon’ble Arbitral Tribunal. A copy of the arbitration invocation notice dated February 15, 2024, is hereto annexed and marked as Exhibit J.
15. That the Respondent’s failure to deliver conforming goods in their entirety precludes its entitlement to the final payment of ₹72,00,000. The defective goods supplied, with a 37% failure rate as evidenced by the Quality Assurance Failure Report dated August 5, 2023, did not meet the standardised quality requirements set forth in Schedule B of the Agreement, rendering them unusable for the Claimant’s smart home automation project. A copy of the Quality Assurance Failure Report dated August 5, 2023, is hereto annexed and marked as Exhibit D.
16. That the Respondent’s breaches caused significant financial losses to the Claimant, including the cost of defective goods (₹96,00,000), additional procurement costs (₹28,00,000), and delays that impacted the Claimant’s product launch timeline, resulting in lost market opportunities. The Respondent’s retention of ₹96,00,000 for non-conforming goods constitutes unjust enrichment.
17. That as per Clause 7.1 of the Agreement, the Respondent is liable to pay liquidated damages at the rate of 0.5% of the total contract value per week of delay, subject to a maximum cap of 5% of the total contract value (₹12,00,000). For the delay of 22 days in the delivery of the Phase 2 production batch, the Respondent is liable to pay liquidated damages amounting to ₹3,60,000.

PRAYER

Therefore, in view of the aforesaid facts and circumstances, it is most respectfully prayed that this Hon’ble Arbitral Tribunal may graciously be pleased to:

A. Pass an Award directing the Respondent to pay a sum of ₹96,00,000 towards refund of the amount paid for defective goods that failed to meet contractual quality standards, along with interest at the rate of 12% per annum from 5 August 2023 till the date of actual payment, which as of June 2025 amounts to approximately ₹23,00,000;

B. Pass an Award directing the Respondent to pay an additional sum of ₹28,00,000 towards financial losses incurred by the Claimant due to procurement from an alternate vendor;

C. Pass an ad interim order in terms of point A.

D. Pass such other or further orders as this Hon’ble Arbitral Tribunal may deem just, fit, and proper in the facts and circumstances of the present case.

VERIFICATION

I, the above-named deponent, do hereby verify that the contents of paragraphs 1 to 5 above are true to my knowledge, and the contents of the remaining paragraphs are based on legal advice and information received by me, which I believe to be true.

Verified at Bengaluru on this _____ day of June, 2025.

MR. VASU RAGHAVAN
Director
Aether Tech Solutions Pvt. Ltd.
(Claimant)

FILED BY:

[Advocate Name]
Advocate for the Claimant
Bar Council Registration No.: _______
Address: _________________________
Phone: ___________________________
Email: ____________________________

Place: Bengaluru
Date: _______, 2025

The exhibits annexed to the Statement of Claim are as follows:

1. Exhibit A: Copy of executed Vendor Supply Agreement dated March 1, 2023.
2. Exhibit B: Delivery schedule and Payment breakdown as per the Agreement.
3. Exhibit C: Payment records evidencing amounts paid to the Respondent (₹72,00,000 + ₹96,00,000).
4. Exhibit D: Quality Assurance Failure Report dated August 5, 2023.
5. Exhibit E: Email correspondence between the parties (April to August 2023).
6. Exhibit F: Procurement invoices from an alternate vendor showing additional costs.
7. Exhibit G: Notice of Dispute dated November 10, 2023.
8. Exhibit H: Legal notices from the Respondent dated December 15, 2023, and February 7, 2024.
9. Exhibit I: Arbitration invocation notice dated February 15, 2024.
10. Exhibit J: Interest calculation chart from August 5, 2023, to June 2025.

You can check this if you would like to view it in PDF.

What AI would have left out if you were not clear

And this is the part I find most interesting.

AI did a great job this time because I was clear. I gave names, dates, events, amounts, and even emails. But what would AI have left out if I were not so thorough?

1. The arbitration clause details – Unless you gave the wording or mentioned the clause number, AI might have written a general placeholder.
2. The interest claim – AI does not assume the interest rate or period unless you give it. You might have got “interest as applicable” instead of 12% p.a. from August 2023.
3. The full relief sought –  AI cannot know if you want damages for reputation, indemnity, or injunction unless you say so.
4. Annexure details – If you had only said “relevant documents”, AI would have left this vague.
5. Jurisdiction specifics – Without saying “Bengaluru” as the seat, the AI may keep it blank or say “to be decided”.

So always remember AI cannot (yet) read your mind. The better your facts, the better its draft.

What you can still tell AI to improve the draft

Before you finalise the claim, you can also:

• Ask AI to include citations of similar arbitration cases.
• Request a summary of the dispute for the tribunal’s reference.
• Add a legal argument section citing breach of contract laws.
• Include a detailed calculation sheet for interest or damages.

And the best part? You can say, “Please redo only the relief sought section to add punitive damages,” and AI will generate just that.

Conclusion

As we come to the end of this guide on drafting a statement of claim using AI, let us pause and reflect on what we have truly learnt.

Using AI for preparing legal documents, especially something as critical as a statement of claim in arbitration, is not about letting the machine replace your legal thinking. It is about using the tool wisely, fully, and with complete clarity.

AI will not think for you. It will not guess what is missing. It will not fill in the gaps on its own. If you forget to mention an important breach, AI will not remind you. If you fail to provide the exact date of the agreement or the interest rate you wish to claim, AI will not invent these details.

This is both a limitation and an advantage.

Why advantage? Because this ensures that you, the lawyer or the claimant, remain in complete control of the facts, the framing of the dispute, and the legal demands. AI simply organises your input into a clear, structured, and legally compliant draft that saves you hours of effort and ensures you do not miss any formal requirement of an arbitration statement of claim.

Think of it like this: AI is your obedient junior who will draft perfectly, format precisely, and follow every legal rule, but only if you feed it the exact and full brief.

This process also reminds you to revisit the fundamentals of claim drafting, completeness of facts, clarity of reliefs sought, correctness of annexures and gives you the freedom to revise, improve, and redraft as many times as you like without time pressure or extra cost.

In short, AI is an excellent tool to make you sharper, more methodical, and more confident as a drafter. But you remain the real lawyer behind the document.

If you truly wish to get the best out of AI while drafting your statement of claim, always ask yourself these five questions:

1. Have I given every essential fact, date, and figure?
2. Have I clearly stated the breaches by the respondent?
3. Have I fully spelt out what reliefs my client seeks?
4. Have I listed all supporting documents?
5. Have I specified the arbitration details (seat, law, arbitrator)?

If the answer to all these is yes, AI will give you a statement of claim that is 90 per cent ready to file.

And if something was left out, you can always go back, correct or add and let AI redraft instantly.

That is the real beauty of using AI in legal drafting.

FAQs

1. Can AI tools like ChatGPT draft a complete and valid statement of claim for arbitration in India?

Yes, AI tools can draft a full statement of claim provided you give complete and clear instructions. AI follows the structure you specify, but it cannot independently verify facts or legal strategy. You remain responsible for accuracy and legal judgment.

2. What will AI miss if I forget to provide full details?

AI will leave out any facts, figures, or legal points that you do not explicitly provide. For example, if you forget to mention the arbitration clause or the exact relief sought, AI will either skip that part or use placeholders such as “[Insert Relief]”. It will not make assumptions on its own.

3. Can AI help in calculating amounts such as interest or damages?

Yes. If you specify the principal amount, rate of interest, and period, AI can generate interest calculations or damage estimates. However, these calculations should always be checked manually for accuracy.

4. Is it necessary to tell AI the seat of arbitration and applicable law?

Absolutely. Unless you specify the seat (city) and governing law (such as the Arbitration and Conciliation Act, 1996), AI may either leave this blank or assume default international norms. Always provide these details.

5. Can AI generate annexures or supporting documents?

No. AI can only list annexures based on your instructions. It cannot produce or verify actual documents such as the agreement, invoices, or emails. You must prepare and attach these documents separately.

6. Can AI suggest legal grounds or causes of action?

Only if you prompt it specifically. If you ask AI to include breach of contract, negligence, or misrepresentation as causes of action, it will do so. Otherwise, it will stick to the factual breaches you describe without adding legal interpretation.

7. Is AI a replacement for legal advice or a qualified lawyer?

Not at all. AI is a drafting tool, not a legal advisor. The final responsibility for correctness, completeness, and legal strategy remains with the human lawyer. AI cannot appear in court or an arbitral tribunal; only you can.

8. What is the best way to use AI for statement of claim drafting?

Provide full, accurate facts. Use clear prompts. Be specific about structure. Ask for revisions if something is missing. Treat AI as your tireless junior, always ready to help but needing clear instructions.