The case involves an appeal by the Football Association of Serbia (FAS) against disciplinary sanctions imposed by UEFA following incidents during a qualifying match for the 2016 UEFA European Championship between Serbia and Albania on 14 October 2014. The UEFA Control, Ethics, and Disciplinary Body (CEDB) initially sanctioned FAS with a three-point deduction in the qualifying round, two home matches behind closed doors, and a €100,000 fine. These sanctions were upheld by the UEFA Appeals Body and later reviewed by the Court of Arbitration for Sport (CAS). The incidents included xenophobic chants, throwing objects onto the field, burning flags, and a drone carrying a nationalist banner that led to a pitch invasion by Serbian supporters, resulting in violent altercations with Albanian players.
The CAS panel affirmed the principle of strict liability for supporter misconduct, emphasizing its role in deterring hooliganism. It also highlighted the importance of adequate security measures, including trained stewards and documented standards, to prevent such incidents. The panel noted that while it retains full power to review disciplinary disputes, it exercises restraint unless sanctions are evidently disproportionate. The factual background revealed multiple violations, including Serbian supporters chanting xenophobic slogans, throwing flares and rocks, and invading the pitch after a drone displaying a nationalist Albanian banner descended onto the field. The ensuing chaos involved altercations between players and supporters, with disputes over the number of invaders.
FAS argued that the additional sanctions were disproportionate, claiming the incidents were provoked by the drone and that its security measures were stringent. However, the panel found FAS negligent in organizing the match, citing inadequate security deployment and poorly trained stewards. Only 109 out of 947 stewards and 210 out of 4,000 police officers were initially stationed inside the stadium, leaving the field vulnerable. The panel also dismissed FAS's claims of mitigating circumstances, such as the drone's appearance, as foreseeable in high-risk matches. It highlighted FAS's poor disciplinary record, including six sanctions in the past five years, as an aggravating factor.
Ultimately, the CAS panel upheld UEFA's sanctions, finding them proportionate given the severity of the incidents and FAS's responsibility under the strict liability principle. The decision underscores the importance of maintaining discipline in football and the limited grounds for overturning well-justified disciplinary measures. The panel rejected FAS's appeal entirely, confirming the sanctions and dismissing all further requests. The case reinforces the need for strict liability and adequate security measures to ensure safety and order in football matches, particularly in high-risk contexts.