The case involves a dispute between Esteghlal Iran Culture and Sport Private Joint Stock Company (Esteghlal) and the Football Federation Islamic Republic of Iran (FFI), Iran Football League Organization, and Persepolis Football Club. The conflict arose from the cancellation of the Iran Super Cup match scheduled for July 20, 2018, after Esteghlal requested a postponement due to player participation in the 2018 FIFA World Cup and other logistical concerns. The FFI rejected the postponement, and when Esteghlal did not participate, the match was canceled, with Persepolis awarded a 3-0 victory by forfeit. Esteghlal appealed this decision through the FFI's internal disciplinary and appeal processes, both of which upheld the sanctions, leading Esteghlal to file an appeal with the Court of Arbitration for Sport (CAS).
The CAS proceedings, overseen by Sole Arbitrator Ivaylo Dermendjiev, addressed several key legal issues. These included the inadmissibility of counterclaims in CAS appeals, the standing of the parties, the scope of Article R57 of the CAS Code (which grants the panel full authority to review facts and law), the doctrine of apparent authority, and the principle of reformatio in peius (prohibiting worsening an appellant's position on appeal). The CAS clarified that counterclaims are not permitted in appeal arbitration proceedings and that any party seeking to modify a decision must file an independent appeal. The panel also emphasized that standing requires a party to have a direct stake in the dispute.
On the merits, the CAS examined whether Esteghlal had withdrawn from the match or merely sought a postponement. While Esteghlal argued it never formally withdrew, the Sole Arbitrator found that its persistent insistence on postponement, particularly at a critical meeting three days before the match, amounted to a de facto withdrawal. The panel rejected Esteghlal's claim that its representative lacked binding authority, ruling that the representative's actions could be imputed to the club under the doctrine of apparent authority. The CAS also determined that Esteghlal's reasons for postponement—such as player fatigue and injury risks—did not constitute force majeure under Article 61 of the FFI Regulations, which penalizes clubs for match cancellations due to their own actions or omissions.
The CAS upheld the forfeit victory for Persepolis but annulled the additional monetary fine imposed by the FFI Appeal Committee, ruling that the fine violated the principle of reformatio in peius, as it worsened Esteghlal's position without being requested by the opposing party. The panel dismissed counterclaims by the FFI and Iran Football League Organization for financial compensation, deeming them inadmissible under CAS rules. The decision underscored the importance of procedural fairness, the limits of appellate authority in sports arbitration, and the need for clubs to adhere to regulatory obligations, particularly in high-profile competitions. The case highlights the balancing act between organizational authority and clubs' rights in sports governance.