The case involves a dispute over the Olympic qualification system for canoe sprint events, adjudicated by the Court of Arbitration for Sport (CAS). The appellants, including the Italian Canoe Federation (ItCF), the Italian National Olympic Committee (CONI), the British Olympic Association (BOA), and British Canoeing (BC), challenged the International Canoe Federation's (ICF) interpretation and application of qualification rules for the 2016 Rio Olympics. The respondents included the ICF, the Russian Canoe Federation (RCF), the Russian Olympic Committee (ROC), and other national Olympic committees and federations. The dispute centered on the reallocation of athlete quota places, particularly whether unused spots from smaller boat classes (K2) should be reallocated to larger boat classes (K4) or remain within the same event.
The CAS panel outlined key principles for interpreting the Olympic Qualification System (OQS). It emphasized that while policy decisions by the ICF are not subject to review, the federation must correctly apply and interpret its rules, which are subject to CAS scrutiny. The panel favored an objective interpretation of the rules, focusing on their text and purpose. In cases of ambiguity, the panel considered the intent of the sports body, provided it did not blatantly contradict the text. The panel rejected the contra proferentem rule, which interprets ambiguous clauses against the drafter, as it would not fairly benefit either party. It also dismissed the fairness principle, noting it could not override fixed quota allocations.
The dispute arose after the 2015 World Championships, where initial quota places were reallocated due to athletes qualifying in multiple events. The appellants argued that unused K2 quota places should have been reallocated to the next best-ranked teams in the same event, while the ICF reallocated them to K4 events to maximize participation. The appellants claimed this violated the OQS's intent and fairness, citing historical precedent and athlete expectations. The ICF defended its decision, stating it aligned with the OQS's purpose of increasing K4 participation and maintaining competitive quality.
The CAS panel examined the OQS's drafting history and concluded the ICF intended upward reallocation to K4, despite unclear wording. It found no evidence of a "K2 Imperative" as argued by the appellants. The panel upheld the ICF's interpretation, noting it was consistent with the OQS's systematic and teleological purpose. It rejected claims of unfairness, emphasizing the fixed quota system and the need for objective rule application. The panel also dismissed arguments based on athlete beliefs, citing insufficient evidence of shared understanding.
Ultimately, the CAS dismissed the appeals, confirming the ICF's quota reallocations and ordering the appellants to bear arbitration costs. The ruling affirmed the ICF's authority to interpret its rules and allocate quota places in line with the OQS's objectives, prioritizing broader participation and competitive integrity over individual claims. The decision underscored the importance of clarity in sports governance and the CAS's role in resolving disputes over rule interpretation.