The case involves a dispute brought before the Court of Arbitration for Sport (CAS) by FC Lokomotiv against the Football Union of Russia (FUR), the Russian Football Premier League (RFPL), FC Rostov, and the Rostov Regional Football Federation. The dispute centered on the legality of the transfer and registration of a player, G., who was loaned from FC Mitos to FC Rostov. The CAS panel reviewed the case de novo, as per Article R57 of the CAS Code, allowing a full reassessment of facts and law. Under Russian football regulations, a player must be registered with both a regional federation and the competition organizer (RFPL) within a specified period to receive a player’s certificate, enabling participation in official matches. FIFA regulations stipulate that a player can only be registered with one club at a time, and the transfer involves the right to register the player, not the registration itself.
G., a youth national team player, was initially registered with FC Spartak Moscow as an amateur and later as a professional. After his contract expired, he signed with FC Mitos but never played for them. Instead, he was loaned to FC Rostov, where he participated in training and friendly matches. FC Rostov attempted to register G. with the RFPL and the Rostov Regional Federation, but the registration was disputed due to alleged documentation issues. FC Lokomotiv contested G.'s eligibility, arguing his registration was improper and filed claims with the Dispute Resolution Chamber (DRC) and later the Players’ Status Committee (PSC), both of which dismissed their appeals. FC Lokomotiv then escalated the matter to CAS, alleging procedural violations and fraudulent documentation. They sought to annul G.'s registration with FC Rostov, declare the transfer agreements illegal, and secure compensation for legal fees.
The respondents, FUR and FC Rostov, countered by challenging the admissibility of the appeal, asserting that FC Lokomotiv lacked standing to appeal since it did not file a protest after the match and was not a party to G.'s employment agreement. They defended the validity of G.'s registration, stating that all necessary documents were properly submitted and stamped, and that delays in issuing the player’s certificate were due to awaiting the DRC's decision. The CAS panel reviewed all submissions, including evidentiary requests and responses, and ordered the production of specific documents to clarify the registration process. The panel concluded that FC Rostov complied with the registration requirements, rendering FC Lokomotiv’s claims unsubstantiated.
The panel emphasized the distinction between the registration of a player with the RFPL and the issuance of a player's certificate, noting that the latter is separate from the registration process itself. The delay in issuing G.'s certificate was attributed to an administrative error by the RFPL official but did not invalidate the registration. The panel also ruled that the validity of the transfer agreement between FC Mitos and FC Rostov was irrelevant to G.'s registration, citing precedent and Article 21 of the FUR RSTP, which states that registration validity is independent of transfer agreement disputes. The panel dismissed FC Lokomotiv's appeal, upholding the prior decisions by the DRC and PSC, and confirmed the validity of G.'s registration with FC Rostov. The ruling underscored the formal nature of player registration and its independence from underlying contractual disputes, ensuring players' ability to participate in matches without unnecessary legal hindrances. The case highlights the complexities of player transfers and the importance of adhering to regulatory frameworks in professional football.