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CAS 2023 A 9768 (CAS)

Why it matters

This case clarifies the application of sporting succession doctrine in football, particularly when a club ceases to exist and a new club emerges. The CAS upheld FIFA's refusal to treat Melaka FC as successor, emphasizing that shared address and legal form are insufficient without continuity of identity, players, and sporting heritage. It reinforces the need for clear evidence of succession to hold a new entity liable for a predecessor's debts.

Summary

The case involves Brazilian player Adriano Aparecido Narcizo who played for Melaka United FC in Malaysia. After Melaka United failed to pay him, the FIFA DRC awarded him USD 52,000 in outstanding salary and USD 409,000 plus MYR 48,000 as compensation for breach of contract. When Melaka United did not pay within 45 days, the player sought enforcement against Melaka FC, claiming it was the sporting successor. FIFA's Disciplinary Committee investigated and concluded Melaka FC was not the successor. The player appealed to CAS. The Sole Arbitrator examined multiple criteria: name (different), legal form (same), address (same), stadium (same), team colours (different), players (different), ownership (different), competition category (different), history and achievements (different), public perception (different), social media (separate), founding year (different), logo (different), and sponsors (mostly different). While some elements like address and legal form were shared, the majority showed no continuity. The Arbitrator dismissed the appeal, confirming FIFA's decision. The award highlights that sporting succession requires substantial continuity of identity, not just incidental similarities.

The detail

Parties: Adriano Aparecido Narcizo v. Melaka Football Club & FIFA

Case number: CAS 2023 A 9768

Outcome: Appeal dismissed; FIFA Disciplinary Committee decision of 9 June 2023 confirmed; each party bears own costs.

Applicable law: FIFA Regulations on Status and Transfer of Players (RSTP), FIFA Disciplinary Code, CAS Code of Sports-related Arbitration

Issues in play: The key issue was whether Melaka FC is the sporting successor of Melaka United, applying criteria under Art. 25(1) FIFA RSTP and Art. 24(1) FIFA Disciplinary Code, including name, colours, players, ownership, and competition category.

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

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