The case involves an appeal by rhythmic gymnast Alexandra Kiroi-Bogatyreva against Gymnastics Australia (GA) concerning her non-nomination for the 2020 Tokyo Olympic Games. The dispute arose from the 2021 Continental Championships, where Lidiia Iakovleva initially placed first after a successful inquiry increased her score, while Kiroi-Bogatyreva placed second. Kiroi-Bogatyreva challenged the qualification of the Superior Judge who reviewed the initial score, arguing the judge was unqualified, and requested an independent review by qualified judges. The International Gymnastics Federation (FIG), GA, and the International Olympic Committee (IOC) responded by annulling the original results and ordering a rejudging of performances using video footage reviewed by FIG-appointed judges. Kiroi-Bogatyreva refused to consent to this process, leading to her exclusion from the revised selection.
The Court of Arbitration for Sport (CAS) upheld the "field of play" doctrine, which prevents CAS from reviewing decisions made by competition judges or officials unless there is evidence of fraud, arbitrariness, corruption, or bad faith. The doctrine recognizes that CAS lacks the specialized expertise to assess technical aspects of sports performances. Kiroi-Bogatyreva contested the fairness of the rejudging process, arguing that the video recordings were inadequate, with only one camera angle obscuring key aspects of her performance. She also claimed the process breached FIG Technical Regulations. However, the CAS ruled that these complaints fell under the "field of play" doctrine and were not subject to judicial review.
GA defended its decision, stating it followed FIG’s guidelines and nomination criteria, which allocated the quota place to Iakovleva by name. GA argued that Kiroi-Bogatyreva had consented to the rejudging process by signing a declaration and participating in discussions. The Sole Arbitrator, Dr. Tricia Kavanagh, concluded that the appellant’s challenges to judging, scoring, and procedural aspects were all matters within the "field of play" and thus beyond CAS’s scope. Since Kiroi-Bogatyreva did not allege corruption or bad faith, the appeal was dismissed.
The ruling reinforced the principle that technical and procedural decisions by sports officials are final unless misconduct is proven. It highlighted the complexities of athlete selection processes and the importance of adhering to governing rules in high-stakes competitions. The case underscored the limitations of judicial intervention in sports arbitration, particularly in disputes involving Olympic qualification and procedural fairness. The CAS upheld GA’s nomination decision, confirming that the process was reasonable and compliant with regulations. The outcome emphasized the deference given to sports officials in technical matters and the finality of the "field of play" doctrine in such disputes.