TAS 2022 A 9306 Mohamed Trabelsi c. Club Jeunesse Sportive de Kabylie & FIFA
CAS · Football (FIFA / CAS) · Switzerland · 5 Sept 2023
Why it matters
This case clarifies the evidentiary standard for establishing the status of a coach under FIFA regulations, particularly when the club disputes the employment relationship. It confirms that a signed contract, work certificates, and witness statements can suffice to prove a coach's role, and that CAS has full power to review the merits de novo. The decision also reinforces the obligation of clubs to pay salaries and bonuses as contractually agreed.
Summary
Mohamed Trabelsi, a CAF A-licensed coach, signed a one-season contract as assistant coach with JS Kabylie in December 2021. The contract provided a monthly salary of EUR 4,500 (net) and bonuses equal to those of players. From March 2022, the club stopped paying salaries and bonuses. After a formal demand, the club acknowledged the debt but did not pay. Trabelsi filed a claim with the FIFA Dispute Resolution Chamber (DRC), which dismissed it for lack of jurisdiction, finding insufficient proof that Trabelsi was actually employed as a coach. Trabelsi appealed to the CAS. Before the CAS, FIFA changed its position and agreed that the evidence (contract, work certificate, coaching license, witness statements) showed Trabelsi was indeed an assistant coach. The CAS sole arbitrator, applying the FIFA Regulations and Swiss law, found that the DRC had jurisdiction. He then exercised the CAS's full review power (Article R57 of the CAS Code) to decide the merits. The arbitrator held that the club owed EUR 18,000 in unpaid salaries for March–June 2022 and DZD 1,500,000 in unpaid bonuses, rejecting the club's arguments that Trabelsi had not proved the bonus amounts or had failed to perform his duties (video analysis). The arbitrator noted that the club's own payment schedule and the head coach's testimony supported Trabelsi's claims. The CAS annulled the FIFA decision and ordered JS Kabylie to pay the amounts with 5% annual interest from the due dates, plus CHF 2,000 towards Trabelsi's legal costs. The arbitration costs were to be borne entirely by the club.
The detail
Parties: TAS 2022 A 9306 Mohamed Trabelsi c. Club Jeunesse Sportive de Kabylie & FIFA
Outcome: Appeal allowed; FIFA decision annulled; JS Kabylie ordered to pay EUR 18,000 in unpaid salaries and DZD 1,500,000 in unpaid bonuses, plus interest and CHF 2,000 towards legal costs.
Quantum: EUR 18,000 + DZD 1,500,000
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTJ), Swiss law (subsidiary), CAS Code of Sports-related Arbitration
Issues in play: The key issue was whether the FIFA Dispute Resolution Chamber had jurisdiction to hear a claim by a coach who was allegedly employed as an assistant coach. The CAS held that the coach had provided sufficient evidence of his employment, thus the FIFA body had jurisdiction.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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