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CAS 2020 A 6767 (CAS)

Why it matters

This case clarifies the application of res judicata in football disputes, emphasizing that a final decision by a national federation's disciplinary committee can bar subsequent FIFA proceedings on the same matter. It reinforces the importance of exhausting local remedies and the binding effect of domestic decisions under FIFA's regulatory framework.

Summary

Zobahan, an Iranian football club, appealed a FIFA DRC decision that declared its claim inadmissible due to res judicata. The dispute arose when player Reza Shekari unilaterally terminated his contract with Zobahan and later signed with Rubin Kazan. Zobahan had previously filed a complaint before the FFIRI Disciplinary Committee, which issued a final decision on 15 August 2017, stating that the player still belonged to Zobahan. Zobahan then filed a claim with FIFA DRC seeking compensation and sporting sanctions. The FIFA DRC held the claim inadmissible because the FFIRI decision was final and binding on the same parties, subject matter, and legal grounds. On appeal, the CAS Panel applied the triple identity test for res judicata: same parties (Zobahan and the Player), same subject matter (breach of contract and compensation), and same legal grounds (FFIRI Disciplinary Regulations). The Panel found that the FFIRI decision was a final adjudication on the merits, and thus the FIFA DRC correctly declined jurisdiction. The appeal was dismissed, confirming that national federation decisions can have preclusive effect in international football disputes.

The detail

Parties: Zobahan Cultural & Sport Club v. Reza Shekari & Football Club Rubin Kazan & FIFA

Case number: CAS 2020 A 6767

Outcome: The appeal was dismissed and the FIFA DRC decision was confirmed. The claim was inadmissible due to res judicata from the FFIRI Disciplinary Committee decision.

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Articles 13, 17; FFIRI Disciplinary Regulations; Swiss law as procedural law; CAS Code of Sports-related Arbitration

Issues in play: The principle of res judicata (triple identity test) collided with the right to bring a claim before FIFA. The FFIRI decision was final and binding, barring the same claim before FIFA.

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

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