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CAS 2022 A 8598 (CAS)

Why it matters

This case clarifies the standard for notification of decisions by email in CAS proceedings. It confirms that an email is deemed received when it enters the recipient's sphere of control, even if outside office hours, and that a sender's delivery report is sufficient proof absent compelling contrary evidence. The decision reinforces the strict application of appeal deadlines in sports arbitration.

Summary

The Hungarian Football Federation (HFF) appealed a FIFA Disciplinary Committee decision that found HFF liable for discriminatory behavior and other misconduct by its supporters during a World Cup qualifier match between Hungary and England on 2 September 2021. The FIFA Appeal Committee confirmed the sanction: two home matches without spectators (one suspended) and a CHF 200,000 fine. HFF appealed to CAS on 7 January 2022. FIFA argued the appeal was late because the decision was notified by email on 16 December 2021 at 8:40 pm, making the 21-day deadline expire on 6 January 2022. HFF claimed it only became aware of the decision on 17 December 2021 and that the deadline should start from actual knowledge. The CAS Panel applied the 'sphere of control' test: a decision is notified when it enters the recipient's sphere of control, i.e., when the email is delivered to the mailbox, regardless of when it is opened. The Panel found that FIFA's delivery report created a presumption of receipt on 16 December 2021, which HFF failed to rebut. HFF's own letter referred to the decision as 'submitted to us on 16/12/2021'. Therefore, the appeal filed on 7 January 2022 was late and inadmissible. The Panel dismissed the appeal and confirmed the FIFA decision.

The detail

Parties: Hungarian Football Federation v. FIFA

Case number: CAS 2022 A 8598

Outcome: The appeal was dismissed as inadmissible because it was filed late. The CAS Panel confirmed the FIFA Appeal Committee's decision.

Applicable law: FIFA Statutes (October 2020 edition), FIFA Disciplinary Code (2019 edition), CAS Code of Sports-related Arbitration (2021 edition), Swiss law

Issues in play: The key issue was whether the appeal was filed within the 21-day deadline. The Panel applied the 'sphere of control' test to determine when the decision was notified, and held that receipt occurs when the email enters the recipient's mailbox, regardless of actual knowledge.

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

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