The case revolves around a dispute between Antalyaspor A.Ş., a Turkish football club, and Green Horse Football Academy, a Nigerian football club, with FIFA acting as a mediator and later respondent. The conflict arose when Antalyaspor registered an amateur player of Nigerian nationality in March 2019. Initially, Antalyaspor was informed by Hearts FC, another Nigerian club, that the player had only been registered with Hearts FC and Green Horse, with Green Horse allegedly waiving its right to claim training compensation. A transfer agreement was signed between Antalyaspor, Hearts FC, and the player, stating no third party could claim compensation. However, Green Horse later claimed training compensation through FIFA's Transfer Matching System (TMS), asserting the player had been registered with them for an additional year and with another club, Abuja City FC, during his training period.
FIFA's administration issued a proposal requiring Antalyaspor to pay Green Horse €100,000 plus interest, which would become binding if not rejected within 15 days. Antalyaspor failed to respond within the stipulated time, leading FIFA to confirm the proposal as a final decision. Antalyaspor appealed to the Court of Arbitration for Sport (CAS), arguing the proposal was not properly communicated due to restricted access to TMS during the Covid-19 pandemic and that the case involved complex legal issues. The CAS panel ruled that FIFA's use of TMS for communication was valid, as clubs are required to regularly check the system, and emphasized the importance of strict adherence to procedural deadlines. The panel upheld FIFA's discretion in determining whether a case is complex enough to warrant a proposal and rejected Antalyaspor's argument that the proposal was not a final decision, clarifying that FIFA's confirmation letter constituted a binding decision.
The panel also noted that Antalyaspor's failure to respond within the deadline amounted to an implicit acceptance of the proposal, akin to a settlement agreement under Swiss law. The principle of venire contra factum proprium was invoked, preventing Antalyaspor from reversing its position after inducing reliance on its inaction. The panel concluded there were no grounds to revise the decision, as Antalyaspor had not demonstrated exceptional circumstances justifying a review. The CAS upheld FIFA's decision, affirming Antalyaspor was legally bound by the training compensation proposal due to its failure to object within the prescribed time limit.
The ruling reinforced the importance of procedural compliance in FIFA and CAS proceedings, particularly regarding communication through TMS and the consequences of failing to meet deadlines. The case serves as a reminder to football clubs of their obligations under FIFA regulations and the binding nature of administrative proposals when not contested in a timely manner. The final decision underscored Green Horse's entitlement to training compensation, dismissing Antalyaspor's defenses based on procedural and substantive grounds. The arbitrator's reasoning highlighted the necessity of clarity in legal communications and the importance of exhausting all internal remedies before pursuing an appeal. The case concluded with the CAS dismissing Antalyaspor's appeal and confirming the binding nature of FIFA's decision.