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CAS 9948 & 10080 (CAS)

Why it matters

This award clarifies the application of Article 17(1)(ii) of the FIFA RSTP regarding additional compensation for players who suffer a pay cut after a club's breach. It confirms that additional compensation of up to six months' salary is mandatory when a player terminates due to overdue payables, but egregious circumstances are required for the maximum. The decision also illustrates the calculation of mitigated compensation by deducting earnings from subsequent contracts.

Summary

The case involves a dispute between Polish football club Lechia Gdansk and player Ilkay Durmus. Durmus signed two contracts with Lechia: the first from July 2021 to June 2023, and the second from July 2023 to June 2026. In June 2023, Durmus notified Lechia of unpaid salaries (February to May 2023) and gave 15 days to pay. Lechia did not respond, so Durmus terminated the contract with just cause on 3 July 2023. He then signed with Gornik Leczna in September 2023 and later with Polonia Warszawa in July 2024. Lechia appealed the FIFA DRC decision that awarded Durmus EUR 759,000 compensation. The CAS sole arbitrator partially upheld Lechia's appeal, reducing the compensation to EUR 578,117.34. The arbitrator found that Durmus had just cause to terminate because Lechia owed four months' salaries, exceeding the two-month threshold under Article 14bis RSTP. The compensation was calculated as the residual value of the second contract (EUR 759,000) minus earnings from subsequent contracts (EUR 206,882.66) plus additional compensation of EUR 57,000 (three months' salary) under Article 17(1)(ii) RSTP, as Durmus suffered a pay cut. The arbitrator also dismissed Lechia's separate appeal against FIFA's procedural closure of its counterclaim, finding it inadmissible. Lechia was ordered to pay costs and contribute to the legal fees of Durmus and Gornik.

The detail

Parties: Lechia Gdansk S.A. v. Ilkay Durmus & Gornik Leczna S.A

Case number: CAS 9948 & 10080

Outcome: Lechia's appeal partially upheld; Lechia ordered to pay player EUR 578,117.34 plus interest for outstanding salaries and compensation for breach of contract without just cause.

Quantum: EUR 578,117.34

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), specifically Articles 14bis and 17

Issues in play: The case involved the interplay between a player's right to terminate a contract with just cause due to unpaid salaries (Article 14bis RSTP) and the calculation of compensation for breach of contract (Article 17 RSTP), including mitigation of damages and additional compensation.

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

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