The Court of Arbitration for Sport (CAS) issued an award on February 4, 2021, resolving a dispute involving the Fédération Française de Canoë Kayak et Sports de Pagaie (FFCK) and the Comité National Olympique et Sportif Français (CNOSF) as appellants, and the International Canoe Federation (ICF), the Argentinian Olympic Committee (COARG), and the Argentinian Canoe Federation (FAC) as respondents. The case centered on the qualification system for the Tokyo 2020 Olympics in canoe sprint events, specifically the reallocation of athlete quota places (AQPs). The sole arbitrator, Prof. Stephan Breidenbach, clarified CAS's authority to review federation decisions, emphasizing that while federations have discretion in applying their rules, CAS ensures these applications align with the rules' text and purpose. The dispute arose from the interpretation of Olympic Qualification Rules, particularly the allocation of AQPs for Men’s Kayak events (K1, K2, and K4), where AQPs are allocated to National Olympic Committees (NOCs) rather than individual athletes.
A key issue was the reallocation of AQPs when an athlete qualified for multiple events, with priority given to the event with the largest boat class. The appellants contested the ICF's application of these rules, arguing that the reallocation process was not correctly followed, particularly concerning the K4 500m event. The arbitrator stressed that rule interpretation must begin with the wording of the rules, considering their ordinary meaning and syntax, and that post-dispute interpretations by the federation cannot override the original rules. The factual background detailed the qualification process, including the 2019 ICF Canoe Sprint World Championships, where AQPs were allocated based on finishing positions and continental representation rules. The appellants challenged the ICF's decisions, arguing they disadvantaged French athletes, but the arbitrator's role was to assess whether the ICF correctly applied its rules, not to impose an alternative interpretation based on fairness.
The case involved Czech athlete Josef Dostal, who qualified in both K1 1000m and K2 1000m but was awarded only the K2 AQP, leading to the reallocation of his K1 AQP. The appellants argued this AQP should have been reallocated to France to field a complete K4 boat, but the ICF ruled that only athletes who participated in the K4 event could count toward filling a boat. The arbitrator examined the rules and concluded that AQPs are event-specific, meaning athletes must have participated in the event for their AQP to count. The ICF's interpretation aligned with the rules' intent to maintain event quality and competitiveness, and past practices supported this view. The arbitrator upheld the ICF's decisions, dismissing the appeal and confirming no additional AQPs needed to be allocated to France.
The ruling underscored the balance between federations' policy-making autonomy and their obligation to apply rules consistently, while respecting the limits of judicial oversight in sports governance. The decision provided clarity on CAS's role in reviewing sports governance disputes, ensuring accountability while respecting federations' discretion in rule-making. The case highlighted the complexities of Olympic qualification and the importance of clear, objective rule interpretation in resolving disputes. The final decision rejected all motions from the appellants, upholding the ICF's reallocation process and concluding the matter.