The case involves a dispute between professional football player Jhonny van Beukering and the Indonesian club Pelita Bandung Raya, along with FIFA, concerning unpaid salaries and contractual breaches. Van Beukering, who held dual Dutch and Indonesian nationality, claimed unpaid wages and housing costs totaling EUR 619,320, arguing that the club failed to meet its contractual obligations. The dispute centered on whether FIFA had jurisdiction to adjudicate the matter, as its competence is generally limited to disputes with an international dimension, meaning the player and club must not share the same nationality. The FIFA Dispute Resolution Chamber (DRC) ruled that since van Beukering had acquired Indonesian citizenship by the time the dispute arose, the case lacked the necessary international dimension and should be resolved by the Indonesian Football Association (PSSI).
Van Beukering appealed to the Court of Arbitration for Sport (CAS), contending that the dispute had an international dimension and should fall under FIFA's jurisdiction. He argued that his Indonesian nationality was merely procedural and that he remained a Dutch national at heart. However, the CAS upheld FIFA's decision, emphasizing that the relevant time for assessing nationality is when the dispute arises, not when the contract is signed. The CAS found that van Beukering’s possession of an Indonesian passport, his participation in the Indonesian national team, and official documentation confirming his citizenship substantiated his Indonesian nationality. The arbitrator dismissed his claims that he did not understand the implications of obtaining Indonesian citizenship or that it was only for football purposes.
The CAS reinforced the principle that FIFA’s jurisdiction is strictly limited to international disputes to respect the autonomy of national associations. It clarified that dual nationality does not automatically create an international dimension unless special circumstances exist, which were absent in this case. The burden of proof rested with van Beukering to demonstrate his claims, which he failed to do convincingly. The arbitrator concluded that the dispute was purely national and should be resolved by the PSSI, dismissing the appeal and upholding the FIFA DRC's decision.
The ruling underscored the importance of jurisdictional clarity in football dispute resolution, ensuring that national associations retain authority over domestic matters. The CAS decision, issued on June 27, 2016, finalized the case, leaving no room for further appeals. It highlighted the procedural fairness of the arbitration process, even though Pelita Bandung Raya did not participate in the hearing. The case serves as a precedent for the handling of nationality and jurisdiction disputes in international sports law, emphasizing the need for clear evidence and adherence to regulatory frameworks. The outcome reaffirmed the division of responsibilities between FIFA and its member associations, ensuring predictability and respect for national governance structures in football disputes.