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CAS 2023 A 9809 (CAS)

Why it matters

This case reaffirms the CAS jurisprudence on sporting succession in football, emphasizing that a club's sporting identity (name, colours, logo, stadium, fan base) can transcend its legal entity. It clarifies that a new club may be held liable for its predecessor's debts even without formal transfer of assets, if it presents itself as the continuation of the old club. The decision also highlights the FIFA Disciplinary Committee's role in enforcing CAS awards.

Summary

The case concerns a dispute over sporting succession between two Ukrainian football clubs. The Original Debtor, FC Karpaty Lviv, was ordered by a CAS award to pay EUR 516,884 to player Cristóbal Márquez Crespo. When the Original Debtor failed to pay, the player sought enforcement against a new club, Karpaty FC (the Appellant), which had emerged after the Original Debtor ceased activities. The FIFA Disciplinary Committee found that Karpaty FC was the sporting successor of the Original Debtor based on shared name, colours, logo, stadium, and public perception, and ordered it to pay the debt plus a fine. Karpaty FC appealed to CAS, arguing that it was a separate legal entity and that the true successor was FC Karpaty Halych. The CAS panel, by majority, upheld the FIFA decision. It applied the test for sporting succession, which considers elements such as name, colours, logo, stadium, fan base, and whether the new club presents itself as the continuation of the old club. The panel found that Karpaty FC had adopted the Original Debtor's identity and was perceived by the public as its successor. The panel also rejected Karpaty FC's argument that the player lacked diligence in enforcing the award. The appeal was dismissed, and Karpaty FC was ordered to pay the debt, interest, and a fine.

The detail

Parties: Karpaty FC v. FIFA, Cristobal Marquez Crespo & FC Karpaty Halych

Case number: CAS 2023 A 9809

Outcome: Appeal dismissed; Karpaty FC confirmed as sporting successor of Original Debtor and ordered to pay EUR 516,884 plus interest and CHF 3,000 to Player, plus CHF 25,000 fine.

Quantum: EUR 516,884 plus interest, CHF 3,000 costs, CHF 25,000 fine

Applicable law: FIFA Disciplinary Code (FDC), CAS Code of Sports-related Arbitration

Issues in play: The principle of sporting succession under Article 21(4) FDC versus the New Club's argument that mere appearance of succession is insufficient without evidence of intent to avoid debts or transfer of assets.

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

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