The case involves an arbitration dispute between the Football Federation of the Islamic Republic of Iran (IRIFF) and FIFA, decided by the Court of Arbitration for Sport (CAS) on 4 November 2009. The dispute originated from an employment contract between IRIFF and a football coach, focusing on unpaid salaries, bonuses, and alleged contractual breaches. The coach's contract, signed in 2004, included bonuses for qualifying for the 2006 World Cup. After Iran's elimination, the coach claimed mutual termination and sought unpaid compensation, while IRIFF accused him of abandoning his duties and demanded a refund of an advance payment. The FIFA Players' Status Committee (PSC) ruled in favor of the coach in 2008, ordering IRIFF to pay the claimed amount plus interest. IRIFF appealed to CAS, arguing procedural flaws and contesting the coach's entitlement to payment.
The CAS panel addressed several legal issues, including the admissibility of the appeal, the compatibility of FIFA's procedural rules, and the standing of FIFA in the dispute. The panel found that FIFA's Article 15, which required parties to request the grounds of a decision within 10 days to preserve appeal rights, conflicted with Article 63(1) of FIFA's Statutes, which imposed no such condition. The panel criticized FIFA for failing to clearly communicate the consequences of missing the deadline, particularly given the novelty of the mechanism and potential language barriers for IRIFF. However, the panel upheld the prior CAS decision validating the 10-day rule, emphasizing procedural efficiency.
The panel also ruled that FIFA lacked standing to be sued, as it was not a party to the original dispute but merely the adjudicating body. The coach, as the opposing party, was not named in the appeal, rendering the proceedings unfair. The panel rejected IRIFF's late-filed evidence, citing procedural non-compliance, and dismissed the appeal in full, as no legal remedy could be granted against FIFA. The panel affirmed the validity of the mutual termination agreement under Swiss law, noting that IRIFF failed to prove damages or provide notice of termination for unauthorized absence.
Ultimately, the CAS upheld the FIFA PSC's decision, reinforcing the importance of procedural clarity, contractual representation, and adherence to higher-ranking statutes in sports governance. The case underscores the complexities of employment disputes in international sports and the necessity for parties to understand and comply with procedural requirements. The panel recommended clearer communication of appeal procedures and suggested integrating Article 15 into FIFA's Statutes to avoid future conflicts. The decision highlights the balance between procedural efficiency and fairness in arbitration.