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2016 Athletics / Athlétisme Doping Upheld English Ordinary Procedure

Arbitrators

President: Lars Halgreen

Decision Information

Decision Date: June 22, 2017

Case Summary

The case involves an arbitration by the Court of Arbitration for Sport (CAS) between the International Association of Athletics Federations (IAAF) and the All Russia Athletics Federation (ARAF), along with athlete Natalya Evdokimova, concerning allegations of blood doping based on irregularities in Evdokimova’s Athlete Biological Passport (ABP) from 2009 to 2014. Due to ARAF’s suspension, the IAAF directly referred the matter to a CAS Sole Arbitrator, bypassing ARAF’s usual role. The arbitrator applied the principle of tempus regit actum, meaning procedural matters followed current regulations, while substantive issues adhered to the rules in place during the alleged violations.

The IAAF’s case relied on Evdokimova’s ABP data, which showed abnormal hemoglobin (HGB) and reticulocyte (RET%) levels, suggesting blood doping to enhance performance. An expert panel unanimously concluded the data indicated prohibited blood manipulation, with high HGB levels before competitions contrasting with lower baseline levels. The panel affirmed the ABP’s reliability for establishing anti-doping violations. Evdokimova and ARAF failed to respond to the allegations or participate in the proceedings, leaving the IAAF’s evidence unchallenged.

The arbitrator found aggravating circumstances, including Evdokimova’s prolonged involvement (nearly five years) in multiple doping offenses and a systematic doping scheme likely involving medical support. The IAAF sought a four-year ineligibility period and disqualification of all results from 2009 to 2016. However, the arbitrator ruled that extending disqualification beyond the last proven doping instance in 2012 would be disproportionate, as delays in the investigation were procedural rather than evidence of ongoing violations. Consequently, Evdokimova received a four-year ban starting from her provisional suspension date (April 14, 2016), and only results from August 17, 2009, to May 29, 2012, were disqualified, including forfeiture of titles and prizes.

The case underscores the ABP’s role in anti-doping enforcement and the importance of proportionality in sanctions. The arbitrator balanced strict anti-doping measures with fairness, ensuring penalties were evidence-based and not unduly harsh due to procedural delays. The decision reaffirms the validity of ABP analysis while emphasizing careful consideration of sanction durations to align with proven violations. The ruling aligns with CAS jurisprudence, highlighting the consequences of systematic doping and the need for evidence-driven disqualification periods.

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