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Published by Enhelion, 2019-11-24 08:06:13





WHAT WILL WE LEARN? It is the responsibility of everybody with any

• The meaning and importance of Code involvement in any sports to ensure that they
of Conduct. remain safe places to be free from
discrimination, fear and where possible, risk.
• The Inter-disciplinary procedures A critical component of maintaining a quality
• On field offences on the players. sports culture is to set standards of acceptable
• An understanding related to the behavior which must be up held by all involved
in the particular sport and participating in any
dispute resolution bodies. sport related activities and competitions.1
• Importance of Arbitration in Sports.
• Court of Arbitration for Sports.

• Provisions for appeals. An important tool for defining and

• Provision for challenging decisions communicating acceptable standards of

behavior is a documented, Code of Conduct.

Ideally the Code of Conduct must apply to all involved in the sports and its activities.2 Different

groups of people which should be covered by the Code of Conduct include:

• Players
• Coaches and team officials
• Team selectors
• Club committee and office holders
• Players
• Parents
• Spectators
• Users of social media

1 Champion, W.T., 2004. Fundamentals of sports law. Thomson/West.
2 Parkhouse, B.L., 1991. The management of sport: Its foundation and application. Mosby-Year Book, Inc..

Having a well-documented Code of Conduct is very positive. The next step is to ensure everybody
has not only read and understands the Code of Conduct but they support and act with the Code. A
good Code of Conduct will be written in a very positive manner, clearly defining the acceptable
and desired standards of behavior. The Code of Conduct should also detail the consequences of
behavior unacceptable under the Code of Conduct.3
Every sport has its own code of conduct which subscribes how a player should behave on field,
what is considered abusive, what amounts as unacceptable behavior and what are the
Some examples of code of conducts for different sports are:

• International Cricket Council (ICC) Cricket Code of Conduct
• FIFA Code of Ethics (For Football)
• FIBA Code of Ethics (For Basketball)
These are the examples of certain international codes on discipline, every national body has its
own code of conduct for the smooth operation and conducting of sporting activities in the country.4

3 Parrish, R., 2003. Sports law and policy in the European Union. Manchester University Press.
4 Supra note at 1.



Disciplinary Hearings are set up to interpret rules and to discipline players and officials who breach
these rules or code of conduct.

The disciplinary bodies of all sports are known as domestic tribunals. They are set up by sporting
organisations to enforce their own rules and codes of conduct. They are not courts of law.

The penalties handed out by sporting tribunals can have a very significant effect upon individuals.
Therefore, it is extremely important that disciplinary proceedings be conducted fairly.5

If an individual refuse to accept the decision of a tribunal, (i.e. decides to fight against the penalty
imposed by the tribunal) they can take the matter to a law court. However, courts of law are
reluctant to intervene in such matters except when:

• The individual suffers a loss of livelihood DID YOU KNOW?
Dean Capobianco the Australian
• There is a flagrant breach of natural justice 200m champion was found positive
• An association does not comply with its own for an anabolic steroid at an IAAF
meet in the Netherlands of May 27.
rules or interprets rules incorrectly
• A decision is made that is outside the powers of

the association (Ultra Vires)

Courts have tended to become more involved as professionalism (the ability to earn substantial
income through sport) increases.


When a tribunal sits, and decides that an individual has breached a code of conduct or has
contravened (broken) the rules of the association, it will decide whether a penalty will be imposed
on the individual.6

5 Gardiner, Simon, Simon Boyes, Urvasi Naidoo, John O'Leary, and Roger Welch. Sports law. Routledge, 2012.
6 Beloff, M., Kerr, T., Demetriou, M. and Beloff, R., 2012. Sports law. Bloomsbury Publishing.

These penalties can be, when necessary, quite drastic. For example:

• Exclusion (banning) of a player from a sport for a period or even permanently
• Fining (financial penalty)
• Loss of selection for a representative team
• These penalties are often necessary to motivate participants in sport to play within the rules,

to set a good example, to abide by rules of conduct, etc.


It is a general proposition of law that decisions affecting the rights of citizens must be reached only
after a fair hearing. The laws relating to a fair hearing are known as the laws of natural Justice.
These laws apply to all courts and tribunals, and will also apply to 'domestic tribunals'.7

The laws of natural justice basically give the 'accused' protection in the following ways:

• The person accused of misconduct should know the nature of the accusation made;
• The person should be given an opportunity to state his or her case;
• The tribunal should act in good faith.
• The accused must have a proper hearing.
• The hearing must be conducted according to the rules of the association concerned.
• Representations must be heard from both sides8
• All the evidence against the accused should be 'on the table'.
• The accused must know the actual charge and which rule has been breached. Being charged

with 'bringing the game into disrepute' under a particular rule is not sufficient.
• If tribunal proceedings bring out evidence suggesting further charges it is wise to adjourn

until the accused could consider the ramifications of such additional charges.
• The accused should be present at a hearing of charges against them. This will not of course

apply where the accused has received proper notification of the proceedings and has no

7 Mitten, M.J. and Opie, H., 2010. Sports law: implications for the development of international, comparative, and
national law and global dispute resolution. Tul. L. Rev., 85, p.269.
8 Supra note at 1.

reason for not attending.

It is important to make sure that the person who is to appear before a disciplinary body is given
every opportunity to attend. If a person who is to appear cannot attend for a good reason, and there
is no need to determine the matter quickly, it might be wise to adjourn the matter until he or she
can be present.
A failure to tell a player that they are being investigated has been viewed as 'flagrant breach of the
rules of natural 'justice' by courts.


Those called before a disciplinary tribunal do not necessarily have the right to be represented by a
lawyer. If disciplinary proceedings are conducted in a fair way by people who have a good
knowledge of the sport and the rules concerned, the courts may agree with no right to legal

If the rules of an association provide for legal or DID YOU KNOW?
other representation, it should of course be
allowed; if it is not, a breach of the rules will have Shane Warne and Mark Waugh, cricket's
occurred.10 highest-paid stars, were disciplined by a
tribunal of the Australian Cricket Board in
In deciding whether legal representation is allowed February 1995 for providing information to
those who draft rules for tribunal hearings need to an Indian Bookmaker.
strike a balance between legalistic complication
when lawyers are involved and the ramifications of
decisions when they are not.


9 Kaiser, R., 1986. Liability and law in recreation, parks, and sports. Prentice Hall.
10 Supra note at 2.

Both sides to any proceedings should generally be allowed to cross-examine (question) the
witnesses of the other, unless the relevant rules exclude the provision. Material not available to
both sides should not be used by the adjudicators in reaching a decision.


A range of penalties should be specified in the rules of an association. Once a person has been
found guilty of a charge, there should be an opportunity to address the tribunal on penalty.11 When
considering the appropriateness of penalty to a particular offence, the tribunal must consider fully
the full effect of the penalty on the guilty party. A long suspension, for example, brings a loss of
income to those paid by the match.12


Members of a disciplinary tribunal or committee must enter into the hearing with an open mind. It
would be improper for an adjudicator to give evidence in proceedings or to be the person who
made the accusation.13
If bias is suspected it must be proved e.g. a committee person of the tribunal told another person
that they were going to 'get even' (with the accused).


Other principles to emerge from the cases are:
• Only those who are members of the committee should be present when decision making
• A tribunal should not surrender its decision - making function to another.
• Decisions should be made on the evidence before the Tribunal - not past reputation.
• Tribunal should not surrender their function to their own legal counsel who had been called
in to assist. However, the committee men of the tribunal are entitled to be have legal

11 Supra note at 4.
12 Anderson, J., 2010. Modern Sports Law: A textbook. Bloomsbury Publishing.
13 James, M., 2013. Sports law. Palgrave Macmillan. James, M., 2013. Sports law. Palgrave Macmillan.


Some interesting examples:

1. Dean Capobianco · The Australian 200m champion was found positive for an anabolic
steroid - stanozolol - at an IAAF meet in the Netherlands of May 27. The Athletics
Australia doping tribunal decided against disqualifying him because investigator Bob
Ellicott QC did not receive the correct paper work from the doping control officer who
took the urine sample.

2. Craig Walton suffered a bike puncture in a selection trial when in the lead. He finished in
34th place and failed to gain selection for World Championships. The tribunal of the
national sporting body ruled its own selectors had erred in excluding Craig Walton from
the world championship team.

3. Shane Warne and Mark Waugh, cricket's highest-paid stars, were disciplined by a tribunal
of the Australian Cricket Board in February 1995 for providing information to an Indian
Bookmaker. There was a great deal of concern that such dealing with a bookmaker could
be evidence of "match fixing".


There is no specific law which relates to sport and at times already established laws have to be
applied to the sporting context. Specifically, in relation to professional sports in India, the law has
being used as have the essence of contract law and criminal law in relation to the actions of
supporters and certain individuals in selling of tickets for sporting matches.14

However, it isn’t simply professional sport that can come under the guise of the law certain acts
involved with any sport whether it be amateur or professional will attract the law, most notably
the criminal law.


The criminal offences of common assault, simple hurt and grievous hurt are governed by the Indian

Penal Code and in certain situations can be applied to

conduct that occurs on the sporting field of play. PONDER UPON THIS...

These days it is much more common for the courts to In a football match one participant
find that conduct on the sporting field of play committed a horrendous tackle on an
constitutes a criminal offence developed through case opponent just as the opponent had
law rather than establishing a statute to develop these scored the winning goal of the game.
offences in the sporting context. Is this an offence?

The leading case concerning an offence against the

person being committed in the sporting context is concerned with a football match where one

participant committed a horrendous tackle on an opponent just as the opponent had scored the
winning goal of the game. The tackle caused a vast amount of damage to the claimant’s ankle.15

It is often difficult to establish whether an assault or something more serious such as hurt, or
grievous hurt has occurred on the field of play in a sport such as football as fouls and strong tackles
are part of the game often resulting in serious injury.16

14 Supra note at 1.
15 Supra note at 5.
16 Jain, T., 2014. The Draft Prevention of Sporting Fraud Bill, 2013: A Violation of Federal Structure?. All Delhi High

Court Reports, pp.89-94.

It was held in this case even if the offending conduct is a foul it is still necessary to determine
whether the conduct was something quite outside what could be expected to occur in the course of
a football match.

This means that in order for an offence against the person to be established during the course of a
sporting context each case will need to be looked at on an individual basis. What first must be
established are the requirements for Common Assault or Section 319, of the Indian Penal Code of
Simple Hurt or Grievous Hurt under Section 320 of IPC. Once this has been established there must
be a further requirement to establish whether the conduct was outside what could be expected from
a normal football match.17


Whether misconduct happening during a sporting context is in fact criminal will depend upon the
following factors:

• The type of the sport participated in DID YOU KNOW?
• The level at which the sport is
Indian cricket players Ajay Sharma, Azharuddin and
participated in Ajay Jadeja, Manoj Prabhakar have been banned for
• The nature of the act life and 5 years respectively in relation to match-
• The degree of force used fixing claims.
• The extent of the risk of injury
• The state of mind of the defendant

Consequently, if it is often difficult to establish that a criminal act has occurred during the course
of a sporting context.

In the sporting context there may be implied consent to inevitable and reasonable physical contact
and to minor breaches of the rules such as fouls which are said to be commonplace but this will
not be the case where there is a serious assault or battery such as a head butt or a punch.

Consent to serious injury is seen much more in sports where offences to the person are said to be

17 Supra note at 4.

commonplace such as boxing or fencing so it may be much more difficult to prove that a criminal
act has taken place in the context of one of these sports.18
To establish that consent has been given we can look at the decisions from the case involving the
footballers where it was stated that the players who participate in sport consent to certain contact
even if it causes, through unfortunate accident, injury which may be or a serious nature. However,
footballers do not consent to deliberately being punched or kicked with such actions constituting
an assault.
To establish whether consent has been given for an offence against the person we need to look at
what would usually be consented to in that sport. If we take the example of boxing a boxer would
consent to being punched and would even consent to a low blow as often this happens by accident
during the course of a boxing match. What they would not consent to however, would be a head
butt or biting of an ear.

Recently, corruption and match fixing charges were thrown up in Indian Cricket by Abhijeet Kale,
a Maharashtra Player. It was only about few years back, when the racket of 'match fixing' in Indian
cricket came to fore when players like Ajay Jadeja, Azharuddin and Manoj Prabhakar were all
charged with 'fixing' the matches. Although Indian players Ajay Sharma, Azharuddin and Ajay
Jadeja, Manoj Prabhakar has been banned for life and 5 years respectively, still this issue is in
controversy because there is nothing in any of the Indian law which brings Match Fixing under
crime. There are latches and loopholes to control the offence of match fixing under current Indian
legal system.

18 Houlihan, B., 2004. Civil rights, doping control and the world anti-doping code. Sport in society, 7(3), pp.420-437.

Strange it would sound that 'match fixing' has not been It is much more common for the
defined in any law. The only place where one can look courts to find that conduct on the
into the definition of match fixing comes from CBI sporting field of play constitutes a
Report on Match Fixing allegations. While inquiring criminal offence developed
into the matter CBI defined 'Match Fixing'19 as through case law rather than
through a statute.
(i) instances where an individual player or group of
players received money individually/collectively to

(ii) instances where a player placed bets in matches in which he played that would naturally
undermine his performance;

(iii) instances where players passed on information to a betting syndicate about team composition,
probable result, pitch condition, weather, etc.,

(iv) instances where groundsmen were given money to prepare a pitch in a way which suited the
betting syndicate; and

(v) Instances of current and ex-players being used by bookies to gain access to Indian and foreign
players to influence their performance for a monetary consideration."

First of all, by looking at this definition it gives an impression as this definition applies to players
and players only. It does not anywhere talks about passing of information to a betting syndicate by
coach or selector themselves or any other person related to cricket team? Do these persons come
under the meaning of ‘player?’20 A player is one who plays on the ground, not any person related
to cricket. Further, there might be situations where player bets on himself to egg him on to do
better. This may be done with bona fide intention to play better. Whether these situations can be
covered by this definition? Certainly not! Therefore, match fixing should be defined something
like this- "Match Fixing is an instance where a player(s) or official(s), directly or indirectly do/does

19 Anderson, L., 2009. Writing a new code of ethics for sports physicians: principles and challenges. British journal
of sports medicine, 43(13), pp.1079-1082.
20 Hill, D., 2010. A critical mass of corruption: why some football leagues have more match-fixing than others.
International Journal of Sports Marketing and Sponsorship, 11(3), pp.38-52.

an undue favour to somebody including himself by harming the basic spirit of the game.21


It is said that match-fixing is cheating the government, the public, especially the millions of cricket
fans. Underplaying and nexus with bookies are acts of cheating for pecuniary benefits. But from a
legal point of view according to s.415 of IPC Whoever, by deceiving any person, fraudulently, or
dishonestly induces the person so deceived to deliver any property to any person, or to consent
that any person shall retain any property, or intentionally induces the person so deceived to do or
omit to do anything which he would not do or omit if he were not so deceived, and which act or
omission causes or is likely to cause damage or harm to that person in body, mind, reputation or
property, is said to cheat.22

Explanation to this section says that- A dishonest concealment of facts is a deception within the
meaning of this Section. For interpreting this section for purposes of match fixing one has to look
into definition of word 'Dishonestly' given in section 24 of IPC which reads as - Whoever does
anything with the intention of causing wrongful gain to one person, or wrongful loss to another
person is said to do that thing dishonestly."23 The courts while interpreting s.24 has made clear
that just because someone has suffered a wrongful loss, it does not mean that the act that caused it
was a dishonest act.

It was laid down in the case of Ahmed v. State of “The origins of doping in sports go
Rajasthan24, that the act becomes a 'dishonest' only back to the very creation of sport
when there is an intention, irrespective of the result. itself such as ancient usage of
Now in case of match fixing whether there is an substances in chariot racing…”
element of 'dishonest concealment of fact' and whether

it causes a wrongful loss or wrongful gain to someone.

When a player conceals the fact of receiving money from punters or bookmakers, it can be

construed as 'dishonest concealment of fact'. The fact that they cause wrongful gain to themselves

21 Supra note at 15.
22 Pollack, J.M., 1998. Take My Arbitrator, Please: Commissioner in Best Interests Disciplinary Authority in

Professional Sports. Fordham L. Rev., 67, p.1645.
23 Section 24, Indian Penal Code, 1860.
24 Ahmed v. State of Rajasthan, 1967 Cri L.J. 1053 Raj.

construes wrongful loss to spectators.25

But to bring this 'dishonest concealment' under Cheating one has to prove intention to cause
wrongful loss to spectators. In my view this wrongful loss to spectators is mere consequence of
this act and is only incidental and thus lacks the intention of causing wrongful loss. So, who
cheated whom? Could those who placed illegal bets deemed to have been cheated by a fixed
match? But it is not the case. Thus, we find that Match-Fixing is not covered under IPC.


According to s.13 (1) (d) (ii) of POC Act 'a public servant is said to commit the offence of criminal
misconduct, if he by abusing his position as a public servant, obtains for himself or for any other
person any valuable thing or pecuniary advantage.' To bring the act of match fixing one has to
bring 'cricketers' under 'public servants'. S. 2 (c) (viii) defines public servant as a person who holds
an office by virtue of which he is authorized or required to perform any public duty. But do
cricketers really do any public duty. Cricketers are mere professionals governed by independent
contracts whose job is to entertain people by playing cricket. They do nothing sort of public duty.
Thus, cricketers do not come under Prevention of Corruption Act, 1988.

In summing up, provisions of law are not stringent enough o control the offence. It is high time
now for the authorities to swing into action. There is a need to amend present law to bring 'match
fixing' under crime. Unless nipped in bud at the earliest, it is likely to cause turbulence.


In competitive sports, doping refers to the use of banned athletic performance-enhancing drugs by
athletic competitors, where the term doping is widely used by organizations that regulate sporting
competitions. The use of drugs to enhance performance is considered unethical, and therefore
prohibited, by most international sports organizations, including the International Olympic

Historically speaking, the origins of doping in sports go back to the very creation of sport itself.
From ancient usage of substances in chariot racing to more recent controversies in baseball and

25 Haberfeld, M.R. and Sheehan, D., 2014. Match-fixing in International Sports. Springer.
26 Thieme, D. and Hemmersbach, P. eds., 2009. Doping in sports (Vol. 195). Springer Science & Business Media.

cycling, popular views among athletes have varied widely from country to country over the years.
The general trend among authorities and sporting organizations over the past several decades has
been to strictly regulate the use of drugs in sport. The reasons for the ban are mainly the health
risks of performance-enhancing drugs, the equality of opportunity for athletes, and the exemplary
effect of drug-free sport for the public. Anti-doping authorities state that using performance-
enhancing drugs goes against the "spirit of sport".27

Many sports organizations have banned the use of performance-enhancing drugs and have very
strict rules and penalties for people who are caught using them. The International Amateur Athletic
Federation, now the International Association of Athletics Federations, were the first international
governing body of sport to take the situation seriously. In 1928 they banned participants from
doping, but with little in the way of testing available they had to rely on the word of the athlete
that they were clean. It was not until 1966 that FIFA and Union Cycliste Internationale (cycling)
joined the IAAF in the fight against drugs, followed by the International Olympic Committee the
following year.28

Progression in pharmacology has always outstripped the ability of sports federations to implement
rigorous testing procedures but since the creation of the World Anti-Doping Agency in 1999, it
has become more effective to catch athletes who use drugs. The first tests for athletes were at the
1966 European Championships and two years later the IOC implemented their first drug tests at
both the Summer and Winter Olympics. Anabolic steroids became prevalent during the 1970s29
and after a method of detection was found they were added to the IOC's prohibited substances list
in 1975.

Over the years, different sporting bodies have evolved differently in the struggle against doping.
Some, such as athletics and cycling, are becoming increasingly vigilant against doping. However,
there has been criticism that sports such as football (soccer) and baseball are doing nothing about
the issue, and letting athletes implicated in doping away unpunished.30

Some commentators maintain that, as outright prevention of doping is an impossibility, all doping

27 Lippi, G. and Guidi, G., 1999. [Doping and sports]. Minerva medica, 90(9), pp.345-357.
28 Burns, C.N., 2006. Doping in sports. Nova Publishers.
29 Jeschke, J., Nekola, J. and Chlumský, J., 1999. [Doping in sports]. Casopis lekaru ceskych, 138(10), pp.291-297.
30 Ibid.

should be legalised. However, most disagree with this, pointing out the claimed harmful long-term
effects of many doping agents. Opponents claim that with doping legal, all competitive athletes
would be compelled to use drugs, and the net effect would be a level playing field but with
widespread health consequences. Considering that anti-doping is largely ineffective due to both
testing limitations and lack of enforcement, this is not markedly different from the situation already
in existence.31

Another point of view is that doping could be legalized to some extent using a drug whitelist and
medical counseling, such that medical safety is ensured, with all usage published. Under such a
system, it is likely that athletes would attempt cheat by exceeding official limits to try to gain an
advantage; this could be considered conjecture as drug amounts do not always correlate linearly
with performance gains.32


There is no denying the fact that sports is a big industry in the world. So much so that 3 % of
worldwide GDP comes from sports. In India sport approximately amounts to 0.5% of the
Government of India expenditure. Since there are various methods designed to resolve dispute of
other goods and services of such high value, should sports be different?

The essence of quick dispute resolution in sports POINTER
cannot be stressed enough. This is particular to
sports because in sports the careers of “The draft National Sports Development
sportspersons are short, they get paid a huge sum Bill 2011, released on the MYAS website in
of money for weekly work and the underlying risk February 2011 has sought to set up an office
of injuries and form is very big. It is because of of Sports Ombudsman to resolve dispute
these very facts that the question of resolution of in sports.”
sports dispute becomes even more important.33

In sports, some disputes are of purely commercial contractual disputes, some are regulatory and

31 Supra note at 29.
32 Pirnay, F., 2001. [Doping in sports]. Revue medicale de Liege, 56(4), pp.265-268.
33 Manley, A., Palmer, C. and Roderick, M., 2012. Disciplinary power, the oligopticon and rhizomatic surveillance in

elite sports academies. Surveillance & Society, 10(3/4), p.303.

others can be quasi criminal. Necessarily all disputes in sports have a commercial impact, since
even a mere disciplinary proceeding against a player may lead to his ban and may have a huge
financial impact on his career, the performance of the club and the image of his sponsors. The
sports dispute resolution does not necessarily have a fixed hierarchy or method. Parties involved
in sports disputes have three ways of resolving such a dispute. First, by complaining to the internal
authorities available within the sporting federations both national and international disputes can
be resolved. Secondly, disputes can be settled by instituting a civil or criminal suit in a court of
law and thirdly through a body of alternate dispute resolution (ADR). It is debatable which method
should be chosen to resolve a sports dispute - the traditional one through courts or the modern one
through Alternate Dispute Resolution (ADR).34

If the dispute is within the rules of the game then the procedure set up by the governing body of
the game is to be followed. The governing bodies have certain in built mechanisms like a penalty
during the match or sending a player off from the field. There can also be disciplinary sanctions
imposed, after the event/game by the governing body, questioning the breach of rules by the player.
The procedure by which the governing bodies decide matters should be carefully structured and
applied due to the peculiar position of sports, where the governing body acts as a prosecutor and
the judge.35

For a long time sports dispute resolution in India lacked any sort of definite form. Though some
of the National Sports Federations (NSF) had made efforts to set up some kind of an internal
dispute resolution procedure, these bodies lacked the teeth and the expertise to adjudicate on
matters effectively besides the failure to completely dispense the issue of bias in the decisions.
With the absence of a dispute resolution mechanism at the National Olympic Committee level
(Indian Olympic Association ‘IOA’), the disputes between and/or in the NSFs (particularly relating
to elections, tenure and democratic proceedings of the NSFs) could not be finally decided. The
Supreme Court of India in the Madhya Pradesh Triathlon Association v. Indian Triathlon
Federation had observed that the NSFs instead of fighting amongst themselves in courts, should
engage in the larger good of promoting sports in India. Such disputes between the NSFs could be

34 McCutcheon, P., 1999. Sports discipline, natural justice and strict liability. Anglo-Am. L. Rev., 28, p.37.
35 Supra note at 12.

resolved through a dispute resolution process which could be initiated by the IOA.
For a long period i.e., between 1996 and 2011 (15 years) the IOA failed to set up a sport dispute
resolution body. The Ministry of Youth Affairs and Sports (MYAS) in its draft of the National
Sports Development Bill 2011, released on the MYAS website in February 2011 has sought to set
up an office of Sports Ombudsman to resolve dispute in sports. While this Bill is yet to be tabled
in the Parliament, the IOA has sought to constitute an Indian Court of Arbitration for Sports
(comprising of 8 members) to resolve disputes pertaining to sports under the IOA. Therefore if the
Bill is passed in its current form (as on MYAS website, February 2011) a certain structure of sports
dispute resolution would develop. The first tier of dispute resolution would be within the NSF with
an appeal lying either to the IOA or the Sports Ombudsman as the case may be.36

36 Hill, D., 2010. A critical mass of corruption: why some football leagues have more match-fixing than others.
International Journal of Sports Marketing and Sponsorship, 11(3), pp.38-52.


Arbitration, a form of alternative dispute resolution (ADR), is a legal technique for the resolution
of disputes outside the courts, wherein the parties to a dispute refer it to one or more persons (the
"arbitrators", "arbiters" or "arbitral tribunal"), by whose decision (the "award") they agree to be
bound. It is a settlement technique in which a third party reviews the case and imposes a decision
that is legally binding for both sides.37

Other forms of ADR include mediation (a form of settlement negotiation facilitated by a neutral
third party) and non-binding resolution by experts. Arbitration in India is governed by the
Arbitration and Conciliation Act 1996 (“Indian Arbitration Act”), which is based on the
UNCITRAL Model Law. The Indian Arbitration Act is broadly divided into two parts. Part I
applies to arbitrations held in India, whether domestic or international, and Part II applies to
arbitrations held outside India.38 Part II, incorporates the rules related to international arbitrations
governed by the New York or Geneva Conventions. In sports, the disputes are first referred to the
federations that govern a particular sport and subsequently the international authorities that govern
the sport e.g. in hockey disputes are referred to the Indian Hockey Federation and after that the
International Hockey Federation.39

At a time when sports are becoming more professional and the stakes are becoming higher than
ever, dispute resolution takes on an increasingly important role. In many respects arbitration offers
the most suitable solutions with regards to the rapidity, diversity, incontestability, and
professionalism of the decisions rendered. With regular increase in the number of sports-related
disputes in the country, India requires an independent authority that specializes in sports-related
problems and that is authorized to pronounce binding decisions. The disputes when referred to
courts take a long time to come up with the final decision since the Indian courts are already piled
up with a number of pending cases. 40

There is a need to have an authority for sports that offers flexible, quick and inexpensive method

37 McLaren, R.H., 2000. Court of Arbitration for Sport: An Independent Arena for the World's Sports Disputes, The.
Val. UL Rev., 35, p.379.
38 Supra note at 11.
39 Ibid.
40 Kaufman, S.A., 1995. Issues in international sports arbitration. Bu int'l Lj, 13, p.527.

of resolution of disputes. With the inauguration of India’s first arbitration centre in Delhi in 2009,
India is recognizing the necessity of arbitration for quicker disposal of cases. The increasing use
of arbitration in sport over the last decade has challenged the legal framework in which arbitration
disputes are addressed in many jurisdictions.41


The rapid advancement of "sports law" in Europe and America has meant that disputes that arise
concerning athletes on the one part and their Sports Federations, Olympic Councils and other
sporting bodies on the other hand are quickly and efficiently resolved with the minimum
involvement of judicial bodies, with arbitration and other forms of alternate dispute resolutions
being given preference. The dynamic development of a "Sports Law" has led to the twin concepts
of Lex-Sportiva (technical rules associated with Sporting Law, which regulates the public aspect
and includes the "specificity of Sports" within itself) and Lex-Ludica (the "spirit of sports", of
ethical sporting conduct, sportsmanship, fair play and other aspects which privately regulates
sporting conduct of athletes in tournaments).

The twin concepts were developed through precedents by international institutions such as the
Court of Arbitration for Sports ("CAS"). In fact, the term was coined by Matthieu Reeb, acting
Secretary General of the CAS in 1986. However, prior to setting up of such institutions, and
development of a specific "sports law", the interpretation of sporting disputes was left to Civil
Courts who interpreted law as per their own interpretation of ordinary civil law. As such, the
decisions were fraught with vague enunciations due to the non-appreciation of the "specificity of
Sports." In a majority of cases, the Civil Courts usually decided in favour of the athletes, due to
the nature of arguments advanced. Three decisions given in 1980's and 1990's would clearly
illustrate the flawed decision making process that was employed and the manner in which Civil
Courts decided when confronted with Sports decisions.

The decisions were Gasser v. Stinson42, Harry Renolds and that of Katrin Krabbe. While each of
these cases highlight a different aspect connected to the aspect of doping in Sports, the ingenuity

41 Lei, T.A.N.G., 2009. Comparison between International Sports Arbitration and International Commercial
Arbitration [J]. Journal of Wuhan Institute of Physical Education, 11, p.011.
42 (unreported Q.B.D. June, 15, 1988).

of arguments advanced in these matters go on to show the manner in which athletes used the
Judicial process to get reliefs which would otherwise not be permitted or capable of being
exercised against sports federations.

In Sandra Gasser's case, the material issue was doping. Gasser's advocates argued on the legal
aspect that a ban on doping amounted to restraint of trade. The Courts had no difficulty in
dismissing the argument of IAAF which was centered on arguing that Gasser, as an "amateur"
athlete, did not have any trade, and therefore, there could not be any restraint. The Courts held that
there could not be any amateurism, rather, Gasser was a sportsperson, and as a sportsperson, any
action that infringed her right to compete amounts to a restraint of trade.

In Reynolds' case, spite of the facts, the issues that arose interestingly was the absolute disregard
of IAAF for the Court process, wherein IAAF had remarked that "Courts create a lot of hindrance
in the anti-doping work. But the IAAF doesn't care the least for what the Courts say. The Rules of
IAAF are supreme and IAAF will follow their Rules.43

In Katrin Krabbe's case, the German Athletics Federation had after arriving at a finding that Katrin
Krabbe had partaken in doping, imposed a one-year ban. Not satisfied with the sentence, the IAAF
conducted its own in-house disciplinary procedure and after arriving at a positive decision,
recommended for an additional two-year sentence to run concurrently with the one-year ban.
Krabbe challenged the same as two-year ban was unlawful under the rules of IAAF. The German
Courts found favour in her submissions. Simultaneously, Krabbe preferred an action for loss of
earnings. After nearly eight years, the IAAF entered into private settlement and resolved the

Sports Federations, concerned due to the fact that athletes were getting favourable decisions,
sought refuge in alternate dispute resolution systems such as arbitration. This trend towards
arbitration, therefore has been gaining prominence since the early 1980s. These, in turn, gave
impetus for arbitration, and more particularly, arbitration within the Sports arena at the global

43 David McArdle ‘Reflections on the Harry Renolds Litigation’, Entertainment Law, Vol 2, No 2, Summer 2003
44 Bhatia, V.K., Candlin, C.N. and Engberg, J. eds., 2008. Legal discourse across cultures and systems (Vol. 1). Hong
Kong University Press.

Sports Arbitration as a concept did not receive international attention until the early 1980's. On
30.06.1984, due to all such and further cases, the CAS was proposed to be established with its own
particular Code, which was framed in 1981.

As things stands today, Arbitration holds sway in almost all sports related disputes. Within this
sphere, the CAS holds a unique place as the "Supreme Sports Resolution Authority". Various
domestic arbitration tribunals have also been set up to in various local jurisdictions to deal with
Sports Disputes

Various other jurisdictions have put in place specialised institutions to deal with arbitration in
Sports. One of such institutions is the Asian Council for Arbitration in Sports ("ACAS") with has
been established in China. The Asian Council for Arbitration in Sports has been set up in
collaboration with the Olympic Council of Asia and is meant as a means to diversify the
jurisdiction of CAS. The involvement of the Olympic Councils in the dispute settlement process
would only mean that expert bodies and individuals having speciality in resolving "Sports
Disputes" are appointed to such Panels as may be set up at the regional level, apart from CAS, and
which would act as a "buffer system" and facilitate a diversified dispute resolution system.

As things stand today, the CAS is the major institution involved in dispute settlement with Centres
at Lausanne, New York, Sydney and a recently opened centre at Abu Dhabi. This would only mean
that there would be an immense advancement in resolution of sporting disputes which are resolved
according rules and procedures of CAS.

Within the Indian sports jurisprudence, a positive step was taken in 2011 with the Indian Olympic
Association being directed by the International Olympic Committee to establish an Indian Court
of Arbitration for Sports ("ICAS") which was to be composed of eight Panellists to adjudicate
disputes arising in the sporting arena. The Panellists were retired judges of the Supreme Court of
India and various High Courts. The Panel comprises of HMJ (Retd.) Dr. A.R. Lakshmanan, who
is the Chairperson of the ICAS along with Mr. M.R. Culla, Retired Justices R.S. Sodhi, B.A. Khan,
Usha Mehra, Lokeshwar Prasad and S.N. Sapra.

From a bare perusal of all newspaper information and other information that is available, it is not
clear whether the aforesaid panel is functional, and furthermore, there is no clarity on whether any
hearings have been conducted, whether specific Rules and Regulations have been framed and

whether there are any particular decisions that have been rendered by such a panel within the last
3-4 years. It is believed that since 2011, when news first circulated that such a panel was to be
constituted, no effective steps have been taken, since, to establish this panel.

In fact, if such a panel was functioning, then a recent dispute involving doping of an Indian
Swimmer would have been referred to such a Panel. In reality, the said dispute has been referred
to the Alternative Hearing Centre ("AHC") of the CAS at Abu Dhabi, where the Sole Arbitrator
has in a detailed order dated 08.04.2015 held against the Indian swimmer. It would not be out of
place to state that this is the first case that has been referred to the Abu Dhabi Centre, which merely
goes on to show that resolution of sports is moving towards a more specialised form.

As a concept, the ICAS was a step towards

developing a niche area of law and efficiently POINTER
resolving disputes at the earliest possible instance
without recourse to a long winded litigation The CAS is governed by its own Statutes and
process. However, steps had to be taken to bring Rules of Procedure namely the Statutes of
such institutions into fruition. As the CAS has the Bodies Working for the Settlement of
promoted the AHC at Abu Dhabi, which has been Sports Related Disputes, Code of Sports
set up in association with the Judicial Department Related Arbitration and Mediation Rules.

in Abu Dhabi, similar steps are required to be taken to promote the Indian Court for Arbitration in

Sports. It is believed that if proper steps had been taken to promote and further the cause of sports

arbitration within India, then such a specialised Tribunal would go a long way in effectively and

efficiently resolving sports disputes. In all sports disputes, it is important to realise that the career-

span of most athletes is extremely limited. Achievement of sporting excellence holds primacy of

place for every athlete. Getting entangled in the long winded procedural court process would not

serve any useful purpose for the athletes. Therefore, time bound alternate dispute resolution is one

of the key mechanisms whereby sports disputes can be effectively resolved.45

Another important aspect which cannot be ignored is that the "Sports Management" in India is
strangely deficient, and has no clue about the working of the CAS, the particular Rules and

45 Straubel, M., 2004. Enhancing the performance of the doping court: how the court of arbitration for sport can do its
job better. Loy. U. Chi. LJ, 36, p.1203.

Regulations or what is the manner in which procedural aspects such as challenging of decisions
needs to be resolved. A recent case in point which shows this aspect in stark contrast is that of Ms.
Sarita Devi, where in a matter pending before the Hon'ble High Court of Delhi at New Delhi, the
Counsel for Boxing India simply gave a statement that, in regard to the one-year ban that was
imposed by the International Boxing Association, there is no provision of appeal before CAS.46

It was later shown that CAS Rules specifically permit such an appeal within a defined time-limit.
The fact that the counsel was prompted to take such a course was occasioned due to in part,
incorrect understanding of the particular Rules47 and a clear non-appreciation of the CAS Rules.
This clearly shows that there is a trenchant lack of awareness within the sporting fraternity as the
concerned sports administrators within various Federations and even within the Ministry are
completely nonchalant and unconcerned about gaining knowledge of latest developments in sports.

This leaves the athletes competing under the aegis of such federations in a lurch, as they are
completely dependent on such federations. This aspect was distinctly seen in the case of Ms. Sarita

Sports Arbitration is still a relatively new concept under The dynamic development of a
Indian jurisprudence. A suggestion can be advanced that "Sports Law" has led to the twin
"Sports Arbitration" as a class can be introduced into the concepts of Lex-Sportiva and
Arbitration and Conciliation Act, 1996 giving it a Lex-Ludica.
certain sense of Parliamentary legitimacy or be

incorporated through the means of separate model

conduct rules that federations can take recourse. If such an action cannot be given effect to, there

are always other Alternate Dispute Resolution methods such as Mediation and Conciliation that

could be applied from the existing legal framework to resolve such an impasse. Examples which

can be culled out from existing laws include Section 89 of the Civil Procedure Code, 1908 and

Part III of the Arbitration and Conciliation Act, 1996.48

Having such a Tribunal such as ICAS which can efficiently deal with and resolve the issues of

46 Ibid.
47 Supra note 2.
48 Forster, J., 2006. Global sports organisations and their governance. Corporate Governance: The international journal

of business in society, 6(1), pp.72-83.

sportspersons would go a long way in helping genuine disputes being resolved at the earliest.
It can only be imagined that had there been an effective Alternate Dispute Resolution process in
place, BCCI and IPL related issues, which have occupied national attention could have been
resolved at the earliest without causing undue sensationalism and scandal.
A hope can only be expressed that ICAS commences to exercise its jurisdiction in respect of sports
disputes and to function in an efficient manner. India is a country where sports law is severely
lagging and steps are required to be taken in respect of such disputes so that both athletes as well
as Sports Federations and other ancillary bodies attached with sports in India can move forward
towards realising their sports related goals rather than ponder over how to settle scores against or
with each other.49

49 Reilly, L., 2012. Introduction to the Court of Arbitration for Sport (CAS) & the Role of National Courts in
International Sports Disputes, An. J. Disp. Resol., p.63.


Arbitration exists in international sport through the Court of Arbitration for Sport. All international
disputes relating to sports are referred to it. The most prominent sports dispute resolution forum is
the Court of Arbitration for Sport (CAS) which has its headquarters in Lausanne, Switzerland. The
CAS was created by the International Olympic Committee (IOC) in 1983. It also has two
permanent outposts in Sydney, Australia and New York, USA. It has a minimum of 150 arbitrators
from 37 countries, who are specialists in arbitrations and sports law. They are appointed by the
International Council of Arbitration for Sports (ICAS) for a four year renewable term and need to
sign a ‘letter of independence’. The CAS also has a permanent President who is also the President
of ICAS.50

The body was originally conceived by International Olympic Committee (IOC) President Juan
Antonio Samaranch to deal with disputes arising during the Olympics. It was established as part
of the IOC in 1984. However in a case decided by the CAS, an appealed was made to the Federal
Supreme Court of Switzerland, challenging CAS impartiality. The Swiss court ruled that the CAS
was a true court of arbitration, but drew attention to the numerous links which existed between the
CAS and the IOC. The biggest change resulting from this reform was the creation of an
"International Council of Arbitration for Sport" (ICAS) to look after the running and financing of
the CAS, thereby taking the place of the IOC. CAS is placed under the administrative and financial
authority of the International Council of Arbitration for Sport (ICAS).51

Almost all international sports federations or DID YOU KNOW?
associations which are part of the Olympic
Games require sports disputes arising between The Becky Scott ruling was the first time in
themselves and sportspersons to be decided by Olympic history that a gold medal had been
the CAS. Sporting federations whose sports are awarded to an athlete as a result of a CAS
not part of the Olympics such as Formula I ruling.
where the FIA which is the governing body of
motor sports has its own dispute settlement

50 Greenberg, M.J. and Gray, J.T., 1998. Sports law practice (Vol. 1). Lexis Law Publishing (Va).
51 Kaufmann-Kohler, G., 2001. Arbitration at the Olympics: Issues of fast-track dispute resolution and sports law.

tribunal. Even some sports which are included in the Olympics have their tribunals like football
where its governing body FIFA has its own tribunal. For example, in 1993, a claim of bringing
Formula I into disrepute was brought against former FI champion Alain Prost and the Williams
Renault Team. The matter was however, satisfactorily resolved by the FIA resulting in Prost
escaping a possible ban from competing in the remaining FI races of that particular season.52

A dispute may be submitted to the CAS only if there is an arbitration agreement between the parties
which specifies recourse to the CAS. The language for the CAS is either French or English. In
principle, two types of dispute may be submitted to the CAS:

1. Those of a commercial nature, and

2. Those of a disciplinary nature.


The first category essentially involves disputes relating to the execution of contracts, such as those
relating to sponsorship, the sale of television rights, the staging of sports events, player transfers
and relations between players or coaches and clubs and/or agents (employment contracts and
agency contracts). Disputes relating to civil liability issues also come under this category (e.g. an
accident to an athlete during a sports competition). These so-called commercial disputes are
handled by the CAS acting as a court of sole instance.53


Disciplinary cases represent the second group of disputes submitted to the CAS, of which a large
number are doping-related. In addition to doping cases, the CAS is called upon to rule on various
disciplinary cases (violence on the field of play, abuse of a referee). Such disciplinary cases are
generally dealt with in the first instance by the competent sports authorities, and subsequently
become the subject of an appeal to the CAS, which then acts as a court of last instance. 54


52 Panagiotopoulos, D., 1999. Court of Arbitration for Sports. Vill. Sports & Ent. LJ, 6, p.49.
53 Nafziger, J.A., 2000. Arbitration of rights and obligations in the international sports arena. Val. UL Rev., 35, p.357.
54 Ibid.

The CAS is governed by its own Statutes and Rules of Procedure namely the Statutes of the Bodies
Working for the Settlement of Sports Related Disputes, Code of Sports Related Arbitration and
Mediation Rules. The CAS acquires its jurisdiction in a particular case only through the mutual
consent of the parties involved. Currently, all Olympic
International Federations and many National Olympic POINT OF INFORMATION
Committees have recognised the jurisdiction of the CAS CAS has a minimum of 150 arbitrators
and included in their statutes an arbitration clause from 37 countries, who are specialists
referring disputes to it. The CAS hears approximately in arbitrations and sports law.
200 cases per year. While it was the international
response to the rise in the use of performance-enhancing drugs and the resulting doping cases that
fueled the creation of the CAS, the Court is called upon to assist in a wide range of sport conflicts,
including sponsorship disputes, the eligibility of a particular athlete in accordance with a sport's
constitution, as well as the resolution of disagreements concerning competition results. The
determination of issues arising in doping cases remains a significant portion of the CAS caseload.55


In addition to arbitration CAS also offers mediation services to any requesting parties of a sports
dispute. Unlike arbitration, the mediation process is not binding—the mediator will provide
recommendations, with solutions suggested, but these are not imposed as a result as in the case of
arbitration. Mediations are designed to permit the adverse parties an opportunity to air their
grievances in an atmosphere aimed at conciliation of the dispute.


• Expertise in sports-related disciplines (there are more than 300 arbitrators from 87
countries qualified to hear CAS disputes) whereas a typical civil judge will not likely
possess such sports-specific knowledge.

• Its arbitrators are all high-level jurists and it is generally held in high regard in the
international sports community.

55 Shuli①, G.U.O., 2002. On the Sport's Arbitration System of International Court of Arbitration for Sports [J]. Sports
& Science, 6, p.009.

• Procedure is flexible and informal.
• Expeditious proceeding as cases are heard and determined within a few months from the

date of reference. During the Olympics, awards are required to be made within 24 hours.
• Lower legal cost to the participants
• Also provides mediation services
• CAS is a private procedure and therefore is conducted without the public or media

interference. The arbitrators and CAS staff are obligated not to disclose any information
connected with the dispute.


• In 2003, Canadian cross country skier Becky Scott successfully appealed to the CAS with
respect to her claim that she be awarded the 2002 Olympic gold medal in the 5-km pursuit
event. Russian skiers Olga Danilova and Larissa Lazutina finished first and second
respectively in the competition, with Scott in third place, and each athlete passed their post-
event doping test. Danilova and Lazutina each failed a subsequent doping test administered
in relation to another Olympic cross-country event, when the presence of a prohibited blood
doping agent, darbepoetin, was detected in each skier's sample. Scott appealed her 5-km
race result on the basis that both Russian skiers were engaged in ongoing doping practices.
The Scott ruling was the first time in Olympic history that a gold medal had been awarded
to an athlete as a result of a CAS ruling.56

• In 2005, the CAS arbitration panel ruled that American sprinter Tim Montgomery be
banned from international competition for two years as a result of doping, in spite of the
fact that Montgomery had never failed a doping test. The CAS ruled that it could find a
doping violation on the basis of the third party evidence called against Montgomery, most
of which connected Montgomery to the Bay Area Laboratory Cooperative (BALCO)
athlete steroid scandal that had arisen in the United States in 2003.57

• In February 2010 Five-time Olympic speed skating champion Claudia Pechstein lost her
appeal against a two-year ban for blood doping. CAS dismissed the German’s appeal

56 Wild, A. ed., 2011. CAS and football: landmark cases. Springer Science & Business Media.
57 Ibid.

against a ban imposed by the International Skating Union.58

Setting aside proceedings against CAS arbitral awards may only be filed with the Swiss Supreme
Court due to the seat of CAS tribunals being in Lausanne.



Suspension is a punishment in sport where players are banned from playing a certain number of
future games. These suspensions may be issued for severe infractions of the rules of play (such as
personal fouls), excessive technical, or flagrant fouls for the duration of a season, fights during the
course of the game in which the player was a part of the wrongdoing, or misconduct off the field
(such as illegal or banned substance use).59

Generally, an athlete who is suspended must forfeit his In Football, the showing of red
pay during the course of the suspension, and card to a player generally results
depending on the team's or league's rules, may not be in one or more match suspension
permitted to don his uniform or be present with the for the player.
team during the course of play, which often includes

attending games in the stands as a typical spectator

would. Every sports has its different rule for suspension which is dealt with as per the rules of that

particular sports.


In law, an appeal is the process in which cases are reviewed, where parties request a formal change
to an official decision. Appeals function both as a process for error correction as well as a process
of clarifying and interpreting law.60 Every sport has its own disciplinary code of conduct/ethics
which prescribe the mode and appellant authority to whom the appeal is made upon suspension or
any other action taken against the player/coach/team.

58 Haberfeld, M.R. and Sheehan, D., 2014. Match-fixing in International Sports. Springer.
59 Nafziger, J.A., 1988. International sports law. International sports law.
60 Weiler, P.C. and Roberts, G.R., 1993. Sports and the Law. Text, Cases, Problems, 3.


According to Articles S12, S20, R27 and R47 of the Code, the Appeals Arbitration Procedure is
open for the appeal against every decision rendered by a federation or club and not limited to
disciplinary matters, especially doping cases. In addition, Article R57 empowers the CAS Panels
not only to annul a certain decision, but also to replace a decision by a decision by a decision of
the arbitrators, or to refer the case back to the issuing body.61

Moreover, Article R58 authorizes the Panel to apply the ‘rule of law’ it deems most appropriate
for the case. Thus the Panels may deviate from the laws of the country in which the federation is
domiciled and reach a decision on the basis of laws of another country or other rules of law, such
as general principles of law.62


As per R34, an arbitrator may be challenged if the circumstances give rise to legitimate doubts
over her/his independence or over her/his impartiality. The challenge shall be brought within seven
days after the ground for the challenge has become known.63

Challenges shall be determined by the ICAS Board, The CAS was created by the
which has the discretion to refer a case to ICAS. The
challenge of an arbitrator shall be lodged by the party International Olympic
raising it, in the form of a petition setting forth the facts
Committee (IOC) in 1983.

giving rise to the challenge, which shall be sent to the

CAS Court Office. The ICAS Board or ICAS shall rule on the challenge after the other party (or

parties), the challenged arbitrator and the other arbitrators, if any, have been invited to submit

written comments.64 Such comments shall be communicated by the CAS Court Office to the parties

and to the other arbitrators, if any. The ICAS Board or ICAS shall give brief reasons for its decision

and may decide to publish it.

61 Ibid.
62 Supra note at 45.
63 Supra note at 32.
64 Panagiotopoulos, D., 1999. Court of Arbitration for Sports. Vill. Sports & Ent. LJ, 6, p.49.


The purpose of ICAS is to facilitate the resolution of sports-related disputes through arbitration or
mediation and to safeguard the independence of CAS and the rights of the parties. It is also
responsible for the administration and financing of CAS.65

ICAS is composed of twenty members, experienced jurists appointed in the following manner:

• four members are appointed by the International The CAS hears approximately
Federations (IFs), viz. three by the Association of 200 cases per year.
Summer Olympic IFs (ASOIF) and one by the

Association of the Winter Olympic IFs (AIOWF),

chosen from within or outside their membership;

• four members are appointed by the Association of the National Olympic Committees

(ANOC), chosen from within or outside its membership;

• four members are appointed by the International Olympic Committee (IOC), chosen from

within or outside its membership;

• four members are appointed by the twelve members of ICAS listed above, after appropriate

consultation with a view to safeguarding the interests of the athletes;

• four members are appointed by the sixteen members of ICAS listed above, chosen from

among personalities independent of the bodies designating the other members of the ICAS.

ICAS exercises its functions itself, or through its Board, consisting of the President, the two Vice-
Presidents of the ICAS, the President of the Ordinary Arbitration Division and the President of the
CAS Appeals Arbitration Division.66

65 Ibid.
66 Supra note at 49.

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