The case involves a dispute between the Federació Catalana de Bittles i Bowling (FCBB) and the Fédération Internationale des Quilleurs (FIQ) over FCBB's eligibility to participate in international bowling competitions. The Court of Arbitration for Sport (CAS) was tasked with determining its jurisdiction and the validity of FIQ's decision to restrict FCBB's participation. The CAS outlined three prerequisites for jurisdiction: an agreement between the parties to submit to CAS, a decision by a sports-related body, and the exhaustion of internal legal remedies. The panel found that an email from FIQ's president constituted a formal decision under CAS rules, and FCBB was not required to exhaust internal remedies since FIQ's statutes allowed direct appeal to CAS.
The dispute originated from a 2013 decision by the Catalonia High Court permitting Catalan sports federations to participate directly in international events, provided there was no conflict with Spanish national interests. The Spanish Bowling Federation (FEB), an FIQ member, sought FCBB's expulsion, citing non-compliance with membership criteria. A Spanish court later ordered FCBB to refrain from international competitions without FEB's authorization. FIQ's legal counsel advised against terminating FCBB's membership but recommended compliance with court orders or FEB directives restricting FCBB's participation. FIQ's Executive Board voted to retain FCBB's membership but agreed to abide by these restrictions.
In May 2014, FEB formally prohibited FCBB from participating in FIQ/WTBA/ETBF tenpin events, prompting FIQ to enforce this directive. FCBB appealed to CAS, arguing the decision was unlawful. The CAS panel ruled that FCBB failed to challenge FIQ's decision within the required timeframe, rendering it final and binding. The panel emphasized FIQ's actions were consistent with its statutes and Spanish legal obligations. The case highlights tensions between national legal systems and international sports governance, particularly in disputes involving regional autonomy and federation membership.
FCBB further argued that FIQ's decision violated its rights under FIQ statutes, which guarantee equal participation for member federations, and that no enforceable Spanish court order justified its exclusion. FIQ maintained its September 2014 letter was not an appealable decision and stressed FCBB's failure to challenge an earlier February 2014 ruling. The CAS sided with FIQ, upholding FCBB's exclusion from the championships. The panel also dismissed FCBB's request for provisional measures, as the main appeal was dismissed.
The CAS panel examined jurisdiction, admissibility, applicable law, and the case's merits. It confirmed jurisdiction under Article R47 of the CAS Code and noted the appeal was filed within the 21-day deadline stipulated by Article R49. The applicable law included FIQ's regulations and, subsidiarily, U.S. law, where FIQ is domiciled. The panel found FCBB had ample opportunity to appeal earlier decisions but failed to do so, making them final. FIQ's rejection of FCBB's entry forms for the 2014 World Men Championships aligned with these unchallenged decisions.
Ultimately, the CAS dismissed FCBB's appeal, upholding FIQ's authority to enforce membership rules while acknowledging constraints imposed by national court orders. The decision underscores the importance of procedural compliance and the binding nature of unchallenged rulings in sports arbitration. It also clarifies that communications from sports federations containing binding rulings can be treated as formal decisions subject to appeal. The case concludes without further relief, reinforcing the finality of CAS rulings in such disputes.