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2015 Rugby Doping Upheld English Appeal Procedure

Parties & Representatives

Arbitrators

President: Alexander McLin

Decision Information

Decision Date: March 31, 2016

Case Summary

The case revolves around an appeal by the World Anti-Doping Agency (WADA) against a decision by the Sri Lanka Anti-Doping Agency (SLADA) concerning rugby player Rishan Pieris, who tested positive for metandienone, a banned anabolic steroid, during an out-of-competition test in July 2014. SLADA initially imposed a one-year ban on Pieris, starting from the date of the test. WADA appealed this decision to the Court of Arbitration for Sport (CAS), arguing that the sanction was inadequate under anti-doping regulations. The central issue was whether Pieris intentionally took the prohibited substance. Pieris admitted to consuming tablets called "Anabol" to increase his body weight but claimed ignorance of their contents. However, CAS precedent establishes that athletes are strictly liable for any substances they ingest, and ignorance does not excuse them from responsibility, especially when they fail to verify a product's contents. The arbitrator, Alexander McLin, emphasized that athletes must exercise extreme caution to avoid prohibited substances.

WADA argued that Pieris demonstrated significant fault by knowingly taking a supplement without proper investigation. Under SLADA's Anti-Doping Rules (ADR), the standard sanction for such a violation is a two-year ban, which can only be reduced if the athlete proves no significant fault or negligence. Since Pieris failed to meet this burden, WADA contended that the original one-year sanction was too lenient and sought an additional year of ineligibility. The proceedings before CAS proceeded without a hearing, as WADA opted for written submissions, and the respondents did not participate or object. The arbitrator concluded that Pieris's intentional ingestion of the tablets, combined with his failure to investigate their contents, constituted significant fault. Consequently, the original one-year ban was overturned, and a two-year suspension was imposed, effective from the date of the CAS award.

The CAS confirmed its jurisdiction over the appeal, as the SLADA ADR grants WADA a direct right to appeal without exhausting internal remedies. The appeal was deemed admissible, as WADA filed within the 21-day deadline after receiving the case file. The applicable law was the SLADA ADR, supplemented by Sri Lankan law where necessary. On the merits, CAS found that the SLADA Disciplinary Committee’s decision was non-compliant with the ADR, which mandates a two-year ineligibility period unless the athlete proves "no fault or negligence" or "no significant fault or negligence." The product's name, "Anabole," should have alerted Pieris to its potential contents, given his stated purpose of increasing body weight. CAS concluded that Pieris committed an anti-doping violation under Article 2.1 of the SLADA ADR and imposed a two-year ineligibility period, crediting any time already served.

The final ruling upheld WADA’s appeal, set aside the SLADA decision, and imposed a two-year ineligibility period on Pieris from the date of the CAS award. This decision reinforces the principle that athletes must rigorously verify substances they consume to avoid anti-doping violations and underscores the strict liability framework in anti-doping enforcement, where ignorance is not a valid defense. The case highlights the limited circumstances under which sanctions may be reduced and ensures compliance with anti-doping rules to maintain fairness in sports.

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