The case revolves around a contentious boxing match at the Tokyo 2020 Olympics between Colombian boxer Yuberjen Martínez and Japanese boxer Ryomei Tanaka, held on 3 August 2021. The match concluded with a split decision in favor of Tanaka by a 4:1 score, prompting Martínez, the Colombian Olympic Committee (COC), and the Colombian Boxing Federation (CBF) to file an appeal with the Court of Arbitration for Sport (CAS) Ad Hoc Division. The appeal challenged the judges' decision, alleging bad faith and arguing that Martínez had clearly outperformed Tanaka based on factors such as the number of quality blows landed, technical superiority, and overall competitiveness. The Applicants sought to have Martínez declared the winner, a replay ordered, or Martínez recognized as the rightful semi-finalist if Tanaka could not continue.
The CAS panel, composed of arbitrators from the Netherlands, Chile, and China, evaluated the case under the "field of play" doctrine, a cornerstone of sports arbitration. This doctrine restricts judicial interference in referees' decisions unless there is evidence of fraud, arbitrariness, or corruption. The panel underscored the importance of preserving the finality of sports results, the lack of technical expertise among arbitrators to judge athletic performances, and the potential for system overload if appeals were too easily entertained. The Applicants presented expert opinions and public sentiment to argue the judges' decision was flawed, but the panel noted these alone were insufficient to prove bad faith or justify overturning the decision.
The Respondent, the IOC Boxing Task Force (IOC BTF), defended the judges' ruling, asserting no fundamental rule violations had occurred. The panel concluded the Applicants failed to meet the high burden required to challenge the field-of-play decision, as they provided no concrete evidence of fraud or arbitrariness. Consequently, the CAS upheld the original decision, affirming Tanaka's victory and dismissing the appeal. The ruling reinforced the principle that CAS panels should not reassess technical judgments by on-field officials absent clear misconduct, emphasizing respect for referees' authority and the integrity of competition outcomes.
Further arguments from the Applicants highlighted Martínez's superior technical and tactical performance, including landing more quality blows and demonstrating better movement to avoid strikes. They also pointed to Tanaka's post-bout physical state, requiring assistance to leave the arena, while Martínez exited unaided. The Applicants relied on expert witnesses and public opinion to bolster their claim of an unjust result. The IOC BTF countered that the decision was a valid field-of-play judgment, only reviewable in cases of extreme bad faith or corruption. They noted the bout was close and decided by a split decision per competition rules, with no evidence of bias or misconduct. The Respondent attributed Tanaka's post-bout condition to dehydration and fatigue, common in high-intensity matches, and emphasized the rigorous selection process for referees and judges to ensure neutrality.
The CAS panel confirmed its jurisdiction under the Olympic Charter and CAS Ad Hoc Rules, which mandate arbitration for Olympic-related disputes. It reiterated the field-of-play doctrine's applicability, limiting judicial interference unless clear evidence of fraud or arbitrariness exists. The Applicants acknowledged this doctrine but failed to meet the high threshold for challenging the judges' decision. The panel ultimately upheld the original ruling, stressing the need for finality in sports results and the absence of sufficient evidence to overturn the outcome. The decision reinforced the principle that field-of-play decisions should not be revisited without compelling proof of misconduct.
The panel also dismissed the Applicants' request to replace Tanaka with Martínez in the semi-finals if Tanaka was unable to compete, stating this would amount to rewriting the rules, which already provide for a walkover in such cases. All requests for relief were denied, and the parties were ordered to bear their own costs per CAS Ad Hoc Rules. The decision reaffirmed the finality of field-of-play judgments and the high threshold required for their review, underscoring the importance of respecting referees' authority and maintaining the integrity of sports competitions.