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CAS 2023 A 10204 (CAS)

Why it matters

This case clarifies the application of FIFA's two-year limitation period to claims under settlement agreements with staggered payments, particularly where sporting succession is alleged. It distinguishes between time-barred past instalments and future ones, and confirms that the limitation period runs from each instalment's due date, not from the date of succession. The decision also highlights that CAS may remit cases to FIFA DRC for factual determinations like sporting succession.

Summary

The case involves Hungarian footballer Márkó Futács and a dispute over a settlement agreement with his former Turkish club, Mersin Idman Yurdu Spor Kulübü (Original Debtor). In 2018, the club agreed to pay €330,000 in instalments through 2030. The club was dissolved in 2019, and Futács later claimed that Yeni Mersin Idmanyurdu (Alleged Successor Club) was the sporting successor and liable. He filed a claim with FIFA DRC in August 2023, which was declared inadmissible as time-barred under FIFA RSTP Article 23(3) (two-year limit). On appeal, CAS held that the limitation period applies per instalment: claims for instalments due before 14 August 2021 are inadmissible, but those due from that date are not time-barred. CAS remitted the case to FIFA DRC to determine whether the Alleged Successor Club is indeed the sporting successor, as this factual issue requires further investigation. The award also rejected Futács' conflict-of-interest argument against the club's counsel.

The detail

Parties: Marko Futacs v. Yeni Mersin Idmanyurdu & FIFA

Case number: CAS 2023 A 10204

Outcome: Appeal partially upheld; case remitted to FIFA DRC for further adjudication on sporting succession; claims for instalments due before 14 August 2021 inadmissible, those from 14 August 2021 admissible.

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Article 23(3) (statute of limitations); CAS Code of Sports-related Arbitration.

Issues in play: The two-year statute of limitations under FIFA RSTP Article 23(3) versus the ongoing nature of a settlement agreement with future instalments. The key issue was when the 'event giving rise to the dispute' occurred for limitation purposes.

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

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