The case involves a dispute between Chelsea Football Club and a player, referred to as M., concerning the termination of the player's contract after he tested positive for a banned substance in October 2004. Chelsea terminated the contract, and the Football Association (FA) imposed a seven-month ban, later extended worldwide by FIFA. The player appealed the termination to the Football Association Premier League (FAPL), and both parties agreed to refer the dispute's "triggering elements"—whether the player breached the contract without just cause—to the FAPL Appeals Committee (FAPLAC). Chelsea also filed a claim with FIFA's Dispute Resolution Chamber (DRC) for potential sanctions and compensation. In April 2005, FAPLAC ruled that the player had breached his contract without just cause, a decision upheld by the Court of Arbitration for Sport (CAS) in December 2005. Chelsea then requested FIFA to award compensation, but in October 2006, the DRC ruled it lacked jurisdiction, prompting Chelsea to appeal to CAS.
The CAS panel, composed of arbitrators from Switzerland, the UK, and Israel, examined the case under FIFA regulations, Swiss law, and English law. The key issue was whether the DRC had jurisdiction to impose sanctions and compensation after FAPLAC had determined the breach of contract. The panel concluded that FIFA regulations distinguish between the "triggering elements" of a dispute (decided by national bodies like FAPLAC) and the "remedies" (sanctions and compensation, which fall under FIFA's exclusive jurisdiction). The panel ruled that the DRC had jurisdiction to decide on sanctions and compensation once FAPLAC established the breach, overturning the DRC's earlier decision and directing it to proceed with determining appropriate measures.
A secondary dispute arose over which version of FIFA regulations applied—the 2001 or 2005 version. Chelsea argued the claim was submitted in February 2005, making the 2001 regulations applicable, while M. contended it was filed in May 2006, invoking the 2005 regulations. The panel sided with Chelsea, ruling that the February 2005 letter constituted the formal submission. The panel also dismissed M.'s procedural objections, including challenges to the admissibility of Chelsea's appeal and objections to translated documents, affirming that the dispute was contractual and subject to FIFA's jurisdiction as agreed in the employment contract.
The case highlights the interplay between national football authorities and FIFA in resolving contractual disputes, particularly concerning breaches and subsequent sanctions. It reaffirms FIFA's central role in enforcing disciplinary measures while allowing national bodies to assess liability under agreed conditions. The decision ensures consistency in applying FIFA's regulatory framework across international football disputes. The panel ultimately upheld Chelsea's appeal, set aside the DRC's 2006 decision, and reaffirmed the DRC's jurisdiction to determine sanctions and compensation, referring the case back to the DRC for further proceedings.