The Court of Arbitration for Sport (CAS) issued a ruling on April 28, 2015, in the case between Legia Warszawa SA and UEFA, concerning sanctions imposed on the club for fielding an ineligible player, Bartosz Bereszynski, during a UEFA Champions League match against Celtic FC on August 6, 2014. The player was serving a suspension from a prior disciplinary decision, and his participation led UEFA to declare the match forfeited, imposing a 3-0 loss on Legia Warszawa and extending the player's suspension. The CAS panel, composed of Manfred Nan, Ulrich Haas, and Fabio Iudica, addressed key legal issues, emphasizing that association rules must be interpreted objectively, particularly for indirect members who did not participate in drafting them. The panel clarified that UEFA's regulations distinguish between a player's general eligibility to participate in UEFA competitions and their eligibility to be fielded in a specific match, with suspended players required to be registered on UEFA's List A or B to serve their suspension.
Legia Warszawa argued that UEFA's registration requirement was excessive formalism, but the panel rejected this, noting it served a legitimate administrative purpose. The panel also ruled that the sanction of forfeiting the match under Article 21.2 of the UEFA Disciplinary Regulations was not subject to suspension, as the rule leaves no discretion in its application. The decision highlighted the principle that sporting results should generally remain undisturbed, though Article 21.2 serves as a regulatory exception permitting match results to be amended when an ineligible player is fielded. The panel maintained a restrictive approach in overturning such decisions, requiring proof of bad faith, arbitrariness, or violation of legal principles, which Legia Warszawa failed to demonstrate.
The case originated when Bereszynski, who had received a three-match suspension in February 2014, was registered by Legia Warszawa for the third qualifying round but not included in the squad list for earlier rounds. He appeared as a substitute in the second leg against Celtic, prompting UEFA's disciplinary action. Legia Warszawa appealed to UEFA's Appeals Body, which upheld the decision, citing the club's negligence and the clarity of the regulations. The club then sought expedited proceedings before CAS, requesting provisional measures to participate in the Champions League playoffs, but this was denied. The final CAS award upheld UEFA's decision, reinforcing the importance of strict compliance with eligibility rules and the automatic nature of forfeiture in such cases.
The panel also addressed Legia Warszawa's claim for financial compensation, which UEFA argued was inadmissible as it was raised for the first time at the CAS stage. The panel dismissed the claim, finding no grounds to hold UEFA liable for the club's losses. The ruling underscored the balance between regulatory enforcement and preserving the integrity of match results, concluding that UEFA's application of its rules was justified and proportionate. The decision serves as a reminder of the stringent requirements governing player eligibility in competitive sports and the consequences of failing to adhere to them. The CAS panel's ruling ultimately dismissed Legia Warszawa's appeal, upholding UEFA's sanctions and rejecting all other requests for relief.