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2012 Judo Doping Upheld English Appeal Procedure

Parties & Representatives

Arbitrators

President: Conny Jörneklint

Decision Information

Decision Date: November 8, 2013

Case Summary

The case involves an appeal by the World Anti-Doping Agency (WADA) against the decision of the Anti-Doping Appeal Panel of India (ADAPI) regarding judo athlete Nirupama Devi Laishram, who tested positive for methylhexaneamine, a prohibited stimulant, during an in-competition test at the Senior Judo Championship in Kolkata on January 11, 2012. The Anti-Doping Disciplinary Panel of India (ADDPI) initially imposed only a reprimand with no period of ineligibility, a decision upheld by the ADAPI. WADA appealed to the Court of Arbitration for Sport (CAS), arguing for a standard two-year ineligibility period under the strict liability principle, which holds athletes responsible for any prohibited substances in their samples regardless of intent. The athlete claimed the substance entered her system through cosmetic products containing geranium oil, which she believed was a natural source of methylhexaneamine. She argued the substance could not enhance performance and its presence was unintentional. However, WADA contested this, presenting evidence that geranium oil does not contain methylhexaneamine and that the high concentration in her sample (10,000 ng/mL) suggested oral ingestion rather than cutaneous absorption. The CAS panel, composed of Judge Conny Jörneklint, Mr. Mark Hovell, and Judge Mukul Mudgal, reviewed the submissions and concluded the athlete failed to meet the criteria for eliminating or reducing the sanction. The panel emphasized the strict liability principle and the athlete's burden of proof to justify any reduction. The CAS overturned the ADAPI's decision, imposing a two-year ineligibility period starting from May 1, 2013, with credit for the 89 days of provisional suspension she had served. The panel also disqualified all competitive results from January 11, 2012, onward, including forfeiture of medals, points, and prizes. The case highlights the rigorous enforcement of anti-doping rules and the challenges athletes face in proving unintentional violations, particularly with substances like methylhexaneamine, which have disputed origins and evolving scientific understanding. The decision underscores the importance of consistency in sanctions and the accountability of athletes under strict liability principles.

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