The Court of Arbitration for Sport (CAS) issued a ruling on a dispute between FC Drita and UEFA concerning a forfeited match in the 2020/21 UEFA Champions League preliminary rounds due to COVID-19-related quarantine measures. The case arose when Swiss health authorities placed FC Drita's entire delegation in quarantine after two players tested positive for COVID-19, preventing them from playing a scheduled match against Linfield FC. UEFA declared the match forfeited with a 0-3 loss under Annex I.2 of its Champions League Regulations, which imposes strict liability on clubs unable to field a team due to quarantine orders. FC Drita appealed, arguing that UEFA's decision was procedurally flawed, based on an illegal provision, and violated principles of equal treatment, as other clubs with COVID-19 cases were allowed to reschedule matches.
The CAS panel examined several legal issues, including UEFA's standing as the proper respondent, the jurisdiction of its Appeals Body, and the validity of its strict liability rule. The panel confirmed UEFA's standing, noting it was best positioned to defend the common interests of competition participants. It also upheld the Appeals Body's jurisdiction, finding that Annex I did not override UEFA's general disciplinary regulations, which allowed urgent cases to be referred directly to the Appeals Body. The panel rejected FC Drita's claim that the strict liability rule unlawfully incorporated public law elements, ruling that UEFA retained autonomy in applying its regulations without outsourcing decision-making to public authorities.
On the merits, the panel found that FC Drita had not formally requested rescheduling before UEFA's decision and that the quarantine order did not constitute force majeure, as the club could have taken earlier action. It also dismissed the equal treatment argument, noting that differing national health authority decisions did not violate UEFA's rules. The panel emphasized UEFA's need to enforce strict deadlines to ensure competition integrity, even during the pandemic. Ultimately, the CAS upheld UEFA's decision, concluding that FC Drita was responsible for the match not being played and that UEFA acted within its regulatory framework. The ruling highlighted the challenges of balancing health protocols with fair competition during unprecedented circumstances. The case underscores the importance of procedural adherence and the limitations of challenging sports governing bodies' decisions in emergencies.