The case involves a dispute between Saipa Football Club and Peykan Football Club, along with the Football Federation Islamic Republic of Iran (FFIRI), concerning an alleged illegal substitution during a match in the Persian Gulf Pro League. The match, held on 16 May 2021, ended with a 1-2 victory for Peykan FC, but Saipa FC later contested the result, arguing that Peykan FC had made a sixth substitution, which violated the rules allowing only five substitutions per match. Saipa FC filed a complaint with the FFIRI Disciplinary Committee, which ruled in their favor, declaring the match forfeited 3-0 and imposing a fine on Peykan FC. However, Peykan FC appealed this decision to the FFIRI Appeals Committee, which overturned the ruling, maintaining the original match result.
The dispute was subsequently brought before the Court of Arbitration for Sport (CAS), where a sole arbitrator examined the case. Key legal issues included the applicability of FIFA regulations, the "field of play" doctrine, and the consequences of the sixth substitution. The arbitrator determined that FIFA's Disciplinary Code did not apply to domestic matches under FFIRI jurisdiction unless explicitly stated. Additionally, the "field of play" doctrine limits CAS's ability to review refereeing decisions unless there is evidence of arbitrariness or bad faith, which was absent in this case. The arbitrator also noted a regulatory gap, as neither FFIRI's rules nor FIFA's Disciplinary Code explicitly addressed the consequences of fielding a sixth substitute.
Saipa FC argued that the sixth substitution violated FIFA regulations, particularly Article 22 of the FIFA Disciplinary Code, which mandates a 3-0 forfeit for fielding an ineligible player. They contended that the substitution itself breached the rules, regardless of the player's minimal impact on the match. Peykan FC and FFIRI countered that the referee's decision to allow the substitution was final and could not be reviewed post-match. They emphasized that the substitution occurred in the final minutes, had no effect on the outcome, and that forfeiting the match would be disproportionate.
The Sole Arbitrator upheld the FFIRI Appeals Committee's decision, dismissing Saipa FC's appeal. The ruling underscored the principle that sporting results should generally remain unchanged unless clear regulatory provisions or exceptional circumstances justify intervention. The arbitrator found no evidence of bad faith or arbitrariness and concluded that the referee's error was unintentional. The decision reinforced the importance of adhering to the "field of play" doctrine and the limited scope for post-match reviews of on-field decisions.
The case highlights the complexities of applying sports regulations and balancing fairness with the integrity of match outcomes. It also illustrates the challenges of addressing regulatory gaps and the deference given to referees' decisions in the absence of explicit rules. Ultimately, the CAS ruling affirmed the original match result, emphasizing the need for proportionality and the preservation of sporting integrity.