The case revolves around a dispute between P.F.C. Litex Lovech (Litex), UEFA, and Debreceni VSC (Debrecen) concerning the fielding of an ineligible player, Peter Máté, during a UEFA Europa League match on August 26, 2010. Debrecen fielded Máté for the final three minutes of the match, despite him not being registered for the play-off stage. Litex protested, arguing that under Article 14bis of the UEFA Disciplinary Regulations (DR), they should be awarded a 4-0 default victory, which would qualify them for the next stage instead of Debrecen. The UEFA Control and Disciplinary Body rejected Litex’s protest, upheld the original match result (1-2), and fined Debrecen €15,000. Litex appealed to the UEFA Appeals Body, which confirmed the decision, while Debrecen sought a reduction in the fine based on proportionality, citing a prior case involving Litex where a lesser fine was imposed. Both appeals were dismissed, with costs allocated to the respective clubs.
Litex then brought the case to the Court of Arbitration for Sport (CAS), requesting the UEFA Appeals Body decision be overturned and a default victory awarded. The CAS panel examined whether UEFA’s disciplinary bodies had correctly applied the regulations. Article 14bis DR allows for a default result if an ineligible player is fielded, but only under specific conditions, such as if the opposing team protests or if the ineligibility stems from a disciplinary decision. The panel noted that the use of "may" in the provision indicates discretion, not an obligation, to award a default result. The panel emphasized the principle of proportionality, requiring an assessment of fault or negligence by the club. While Debrecen’s negligence was acknowledged due to poor internal communication, the panel found UEFA’s decision to impose a fine rather than award a default result was within its discretion and proportionate, given the minimal impact of the player’s brief appearance on the match outcome.
The CAS panel upheld UEFA’s decision, rejecting Litex’s appeal and confirming the fine imposed on Debrecen. The ruling reinforced that disciplinary measures must balance the severity of the breach with the fault of the offending party, rather than applying strict liability. The case underscores the importance of internal club procedures to prevent such errors and the discretionary nature of disciplinary sanctions in football governance. The panel also dismissed comparisons to other cases, such as doping or hooliganism, as irrelevant, and referenced a similar case where an administrative error resulted only in a fine. Ultimately, the CAS concluded that awarding a default victory would be disproportionate, as Debrecen did not act willfully or in bad faith, and the ineligible player’s participation had no material effect on the match. The decision clarified that strict liability does not apply in such scenarios, and disciplinary bodies retain flexibility in determining sanctions based on the specific circumstances of each case.