The case involves a legal dispute between Al-Khor Sports Club, a Qatari football club, and Jean-Paul Rabier, a French football coach, concerning the early termination of Rabier's employment contract. The contract, signed on 29 May 2007, stipulated Rabier's employment from 1 July 2007 to 30 June 2008, with specific termination clauses. Article VIII of the contract allowed either party to terminate the agreement with 30 days' notice, and in the absence of just cause or mutual agreement, the breaching party would owe $100,000 as compensation. Rabier's remuneration included a signing fee and monthly salary, with a supplementary agreement adding $100,000 to his compensation but requiring him to refund this amount in case of conflict.
On 7 November 2007, the club terminated Rabier's contract without just cause, prompting him to file a complaint with FIFA. Rabier sought unpaid salaries, the remaining signing fee, the $100,000 termination compensation, and reimbursement for flight tickets and other damages. He also requested the supplementary agreement's refund clause be declared void. In early 2008, Rabier secured another coaching position in Japan, mitigating some losses.
FIFA's Players’ Status Committee partially upheld Rabier's claims in March 2010, ordering the club to pay $237,220, covering unpaid salaries and termination compensation, but rejected other claims. The decision included a 5% annual interest penalty for late payment. The case was appealed to the Court of Arbitration for Sport (CAS), which ruled that both FIFA regulations and Qatari law applied. The CAS panel interpreted the $100,000 termination clause as liquidated damages, meaning Rabier was entitled to the amount regardless of his subsequent employment. The club remained liable for salaries owed before termination, and the duty to mitigate losses did not apply to liquidated damages.
The CAS upheld the FIFA decision, reinforcing the enforceability of contractual termination clauses and the principle of pacta sunt servanda (agreements must be kept). It clarified that liquidated damages cover losses from early termination, including future salaries, but do not absolve the breaching party of obligations accrued before termination. The Panel rejected the club's argument that the signing fee was an advance salary, ruling it was a separate lump-sum payment. Rabier was entitled to the full signing fee of $200,000 and unpaid salaries of $37,220. The Panel also dismissed the relevance of Article 54 of the Qatar Labour Law, which pertains to end-of-service gratuity, as it did not restrict Rabier's contractual entitlements.
The CAS ultimately rejected the club's appeal, upholding the FIFA decision and emphasizing the importance of clear contractual terms and adherence to procedural deadlines. The case underscores the binding nature of agreed-upon compensation clauses and the need for parties to substantiate claims with evidence. The Panel's ruling affirmed Rabier's entitlements under the contract, reinforcing the principle that contractual obligations must be honored.