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CAS 2019 A 6461 (CAS)

Why it matters

This case clarifies that a football club's sporting identity, based on name, colours, logo, stadium, history, and squad, can override its separate legal personality for disciplinary purposes. It confirms that the FIFA Disciplinary Committee may determine sporting succession and impose sanctions on the successor club under Article 64 of the FIFA Disciplinary Code, even if the original debtor club is liquidated. The decision also emphasizes that a creditor's failure to claim in liquidation does not automatically bar disciplinary action if the creditor was not passive.

Summary

Tartu Jalgpallikool Tammeka (the Appellant) appealed a FIFA Disciplinary Committee decision that held it liable for debts of Tartu Jalgpalliklubi Tammeka (the Debtor club), which had been ordered to pay EUR 139,666.66 in training compensation to NK Otok. The Debtor club entered liquidation in 2014 and was deleted from the business register in 2016. The Appellant argued it was a separate legal entity and that the FIFA DRC should have determined succession. The CAS Panel dismissed the appeal, finding that the Appellant was the sporting successor of the Debtor club based on shared name, colours, logo, stadium, and squad. The Panel held that the FIFA Disciplinary Committee had authority to decide succession and apply Article 64 of the FIFA Disciplinary Code. It also rejected the argument that the creditor failed to claim in liquidation, noting the creditor could not have done so before the DRC decision. The Panel confirmed the fine and transfer ban, ruling that the Appellant was liable for the debts of its predecessor.

The detail

Parties: Tartu Jalgpallikool Tammeka v. FIFA

Case number: CAS 2019 A 6461

Outcome: Appeal dismissed; FIFA Disciplinary Committee decision confirmed; Tartu Jalgpallikool Tammeka held liable for debts of predecessor club and fined CHF 15,000.

Quantum: CHF 15,000 fine; underlying debt EUR 139,666.66 plus interest

Applicable law: FIFA Statutes (2019 edition), FIFA Disciplinary Code (2017 edition), CAS Code of Sports-related Arbitration, Swiss law

Issues in play: The case involved the principle of sporting succession, where a new club may be held liable for the debts of its predecessor if it continues the same sporting identity. Also at issue was the creditor's duty to claim debts in liquidation proceedings and the scope of Article 64 of the FIFA Disciplinary Code.

Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗

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