The case involved the International Association of Athletics Federations (IAAF) bringing an anti-doping rule violation against Russian athlete Ekaterina Sharmina and the All Russia Athletics Federation (ARAF) before the Court of Arbitration for Sport (CAS). The allegations were based on abnormalities detected in Sharmina's Athlete Biological Passport (ABP), which showed suspicious blood values indicative of prohibited blood manipulation between March 2011 and August 2015. The IAAF charged Sharmina with violating Rule 32.2(b) of its competition rules, which prohibits the use of banned substances or methods. The case was referred directly to CAS due to ARAF's suspension from IAAF activities, preventing it from conducting a timely hearing.
The sole arbitrator, Prof. Michael Geistlinger, addressed several key legal and procedural issues. He confirmed CAS's jurisdiction under IAAF Rule 38.3, which allows direct referral when a member federation cannot convene a hearing. The arbitrator applied the principle of tempus regit actum, determining that procedural matters follow the rules in force at the time of the act, while substantive anti-doping violations are governed by the rules in place when the violation occurred. The arbitrator noted that an ABP-based violation is not a multiple violation but a continuous one, starting from the date of the first abnormal sample.
The arbitrator emphasized that abnormal ABP values alone do not prove doping; expert interpretation is required to assess whether the deviations suggest a doping scenario. Sharmina failed to provide credible non-doping explanations for the irregularities, such as high-altitude training or medical conditions, leaving the ABP findings unchallenged. The arbitrator also clarified that the ABP Operating Guidelines do not require a minimum number of samples to establish a violation.
Regarding disqualification of results, the arbitrator ruled that Rule 40 of the IAAF Rules applies, mandating disqualification of competitive results. He addressed the fairness exception in the 2012-2013 IAAF Rules, noting that despite its omission in later versions, it must be read in conjunction with the World Anti-Doping Agency (WADA) Code, which requires proportionality. However, he concluded that disqualifying results from the first abnormal sample was justified to correct unfair advantages, as the primary purpose is ensuring fairness for other athletes rather than punishment.
The case underscores the complexities of ABP-based doping cases, particularly in determining violation timelines, evidentiary standards, and the proportionality of sanctions. The arbitrator’s decision reinforced the validity of ABP as a tool for detecting blood doping and clarified procedural and substantive rules governing such cases. The ruling also highlighted the importance of expert analysis in interpreting ABP data and the principle that disqualification aims to preserve competitive integrity rather than solely penalize the athlete.
Ultimately, the arbitrator found Sharmina guilty of an anti-doping rule violation and imposed a three-year period of ineligibility, starting from the date of her provisional suspension (7 December 2015). The decision also disqualified all her competitive results from 17 June 2011 to 5 August 2015, including forfeiture of titles, medals, points, and prize money. The arbitrator emphasized the need for proportionality in sanctions, balancing deterrence with fairness, and referenced prior CAS rulings to justify the decision. The award concluded by partially upholding the IAAF's claims and dismissing all other relief requests, with the option to appeal under IAAF Rule 42.