The case involves a dispute between the International Association of Athletics Federations (IAAF) and the Russian Athletics Federation (RUSAF) along with athlete Ekaterina Volkova, concerning an anti-doping rule violation. The Court of Arbitration for Sport (CAS) issued an award addressing the violation, which stemmed from the re-testing of a sample Volkova provided during the 2008 Beijing Olympics. Initially, the sample showed no prohibited substances, but later analysis revealed the presence of dehydrochlormethyltestosterone (DHCMT), a banned anabolic steroid. The IOC Disciplinary Commission found Volkova guilty of an anti-doping violation in October 2016, disqualifying her results from the 3000m steeplechase event. The case was then referred to the IAAF for further sanctions.
The IAAF, recognizing the IOC’s decision under its own rules, notified Volkova of the violation and offered her procedural options under the IAAF Competition Rules. Volkova failed to respond, leading to her provisional suspension and the case being referred to CAS. The IAAF requested CAS to hear the case as a first-instance body due to RUSAF’s suspended status and Volkova’s lack of response. The case was assigned to a sole arbitrator, who determined that substantive matters would be governed by the rules in place at the time of the violation, while procedural matters would follow the rules just prior to April 2017. The arbitrator confirmed that the IAAF and its members must recognize the IOC’s final adjudication of the violation.
Volkova did not participate in the proceedings or provide any defense, leading the arbitrator to uphold the IAAF’s position. The arbitrator confirmed the anti-doping violation and imposed sanctions, including a two-year period of ineligibility starting from the date of her provisional suspension, with credit given for time already served. The disqualification of results was limited to two years from the sample collection date (August 17, 2008, to August 16, 2010), aligning with the standard ban period had the violation been detected earlier. This decision was based on fairness considerations, given the intentional nature of the violation and the lack of evidence suggesting further violations.
The case highlights the strict liability principle in anti-doping regulations, where athletes are held responsible for prohibited substances in their bodies regardless of intent. It also underscores the procedural mechanisms for addressing violations when one party does not participate, ensuring fair adjudication based on available evidence. The arbitrator’s decision reinforced the importance of adhering to anti-doping rules and the consequences of non-compliance, including disqualification of results and forfeiture of titles, awards, and prizes. The ruling reflects CAS’s role in upholding the integrity of international sports by enforcing anti-doping regulations while balancing fairness in sanctioning.