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CAS 2022 A 9047 (CAS)

Why it matters

This case clarifies that the Covid-19 pandemic does not automatically constitute force majeure justifying unilateral termination of a player's contract without just cause. It reinforces the principle that clubs must continue to pay salaries and cannot use the pandemic as a pretext to avoid contractual obligations, especially when the player is willing to perform but prevented by travel restrictions. The award also confirms that bonuses already earned are payable.

Summary

Korona S.A., a Polish football club, signed a playing contract with Spanish player Iván Márquez Álvarez from August 2018 to June 2020. In March 2020, the player traveled to Spain with the club's permission to accompany his wife for medical treatment. Due to Covid-19 travel restrictions, he could not return to Poland. The club requested his return, but flights were suspended. On 28 March 2020, the club proposed a 50% salary reduction, which the player refused. On 10 April 2020, the club unilaterally terminated the contract citing force majeure (Covid-19) under Polish Civil Code articles 492 and 357. The player claimed wrongful termination and sought unpaid salaries and bonuses. The FIFA Dispute Resolution Chamber (DRC) found the termination without just cause and ordered the club to pay EUR 40,100 (residual value of the contract) plus interest. The club appealed to CAS. The Sole Arbitrator applied FIFA RSTP and Swiss law. He held that the club failed to prove force majeure prevented performance; the player was willing and able to perform but was prevented by government restrictions. The termination was without just cause. The club was liable for the residual value of the contract (EUR 40,100) plus 5% interest from the date of claim. The appeal was dismissed, and the club was ordered to pay CHF 6,000 towards the player's legal costs.

The detail

Parties: Korona S.A. v. Ivan Marquez Alvarez & FIFA

Case number: CAS 2022 A 9047

Outcome: Appeal dismissed; Korona S.A. ordered to pay EUR 40,100 plus 5% interest from 29 March 2022 to the Player, and CHF 6,000 towards legal costs.

Quantum: EUR 40,100

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), Swiss Code of Obligations (SCO), Swiss Civil Code (SCC)

Issues in play: Force majeure (Covid-19) vs. contractual obligations; unilateral termination without just cause under Article 17 FIFA RSTP.

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

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