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CAS 2023 A 9823 (CAS)

Why it matters

This case clarifies the standard of diligence expected from a player-creditor when a club becomes insolvent. It confirms that even if national law provides for ex officio registration of employee claims, the creditor must still take proactive steps to identify themselves. The ruling reinforces that a sporting successor club cannot be sanctioned if the creditor's own negligence contributed to non-compliance.

Summary

Jurica Buljat, a Croatian footballer, had a debt of USD 87,499 from FC Metalist Kharkiv (the Original Club) confirmed by a FIFA DRC decision in 2016. The Original Club went bankrupt in Ukraine, and FIFA informed Buljat in March 2018. Buljat did not participate in the bankruptcy proceedings. Later, a new FC Metalist Kharkiv (the New Club) emerged as the sporting successor. Buljat asked FIFA to discipline the New Club for non-payment. The FIFA Disciplinary Committee closed the proceedings, finding Buljat lacked diligence. Buljat appealed to CAS. The CAS Sole Arbitrator applied FIFA regulations and Swiss law, and considered Ukrainian bankruptcy law. The key issue was whether Buljat was diligent. Buljat argued that under Ukrainian law, employee claims are registered ex officio, so he did not need to act. However, the Arbitrator found that the law required the creditor to file an application or ensure the debt appeared in the club's records. Buljat took no action for almost three years after being informed. Therefore, he failed to show diligence, and no disciplinary sanctions could be imposed on the New Club. The appeal was dismissed, and the FIFA decision confirmed.

The detail

Parties: Jurica Buljat v. FC Metalist Kharkiv & FIFA

Case number: CAS 2023 A 9823

Outcome: Appeal dismissed; FIFA Disciplinary Committee decision to close proceedings confirmed.

Applicable law: FIFA Disciplinary Code (2023 edition), Swiss law subsidiarily, Ukrainian bankruptcy law for factual assessment

Issues in play: The duty of a creditor (player) to be diligent in bankruptcy proceedings vs. the automatic registration of employee claims under Ukrainian law.

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

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