Paris 2024: Court of Arbitration for Sport decisions

CAS Ad Hoc Division

CAS is an international body responsible for resolving sports related disputes. CAS has operated a CAS Ad Hoc Division at each Olympic Games since 1996 in order to resolve disputes arising during the Olympic Games in an efficient manner.  

CAS opened two temporary offices in Paris to provide dispute resolution services both immediately before and during Paris 2024. The offices operated from 16 July 2024 until 11 August 2024. Where an application is made to the CAS Ad Hoc Division, the matter is generally heard by three arbitrators.^[1] A panel of 12 arbitrators was appointed to the CAS Ad Hoc Division for Paris 2024, with three of the arbitrators available remotely^[2]. The arbitrators selected to participate in the CAS Ad Hoc Division are all experienced lawyers, judges or academics who specialise in sports law and/or arbitration. 

Case summaries

As at 25 August 2024, the full award with grounds has been published for 17 of the 19 matters that proceeded before the CAS Ad Hoc Division for Paris 2024. In both matters where the full award has not yet been published, the CAS Panel found it did not have jurisdiction and the applications were unsuccessful.^[3] The decisions published by the CAS Ad Hoc Division for Paris 2024 relate to:

• jurisdiction of the CAS Ad Hoc Division in relation to disputes arising prior to the Olympic Games;
• qualification and selection;
• field of play disputes; and
• espionage.

Jurisdiction of CAS in relation to disputes arising prior to the Olympic Games

Each Panel hearing an application in the CAS Ad Hoc Division must determine whether or not it has jurisdiction to hear the application.

Under Article 1 of the CAS Ad Hoc Division Rules (Rules), the jurisdiction of the CAS Ad Hoc Division is the resolution of any disputes covered by Rule 61 of the Olympic Charter, insofar as they arise during the Olympic Games or during a period of 10 days preceding the Opening Ceremony of the Olympic Games. Rule 61 of the Olympic Charter provides: 

‘Any dispute arising on the occasion of, or in conjunction with, the Olympic Games shall be submitted exclusively to the Court of Arbitration for Sport (CAS), in accordance with the Code of Sports-Related Arbitration.’

The Opening Ceremony for Paris 2024 was held on 26 July 2024, meaning the CAS Ad Hoc Division had jurisdiction in connection with disputes arising on or after 16 July 2024. 

CAS also only has jurisdiction where the applicant has exhausted all the internal remedies available to them under the statutes or regulations of the sports body concerned, unless the time needed to exhaust the internal remedies would make the appeal to the CAS Ad Hoc Division ineffective. 

Nayoka Clunis v. Jamaica Athletics Administrative Association^[4]

Facts 

Nayoka Clunis (Clunis) is a Jamaican hammer thrower and member of the Jamaica Athletics Administrative Association (JAAA). 

On 2 July 2024, World Athletics confirmed the list of athletes who qualified for Paris 2024, including Clunis who was eligible based on her 23rd place World Ranking. On 4 July, JAAA submitted their pre-entry list of athletes for Paris 2024, however inadvertently left off Clunis. This error was said to be due to the impact of Hurricane Beryl in Jamaica and, in particular, its impact on electricity and internet access. On 5 July, World Athletics reallocated places to the next best ranked athletes named by their member federations based on the remaining number of places available. In the absence of the nomination of Clunis, the available place in hammer throw was allocated to an athlete from Ukraine. 

When the error was identified, JAAA sought to have Clunis included in the list of athletes for Paris 2024; however, World Athletics stated Clunis would only be included if an entry cancellation or withdrawal occurred in her event based on the IOC’s Late Athlete Replacement Policy.

On 18 July, Clunis filed an application with the CAS Ad Hoc Division. Submissions were made by Clunis and JAAA, in addition to the IOC, World Athletics, and the Jamaica Olympic Association (JOA). 

Clunis submitted to the CAS Ad Hoc Division panel: 

• an administrative error and the impact of Hurricane Beryl resulted in JAAA neglecting to submit Clunis’ name to World Athletics; and
• the situation was exceptional, and Clunis – as a qualified and selected athlete – should not lose her spot at Paris 2024 due to events that were entirely outside of her control. JAAA supported the submissions of Clunis and sought she be included by World Athletics in the list of athletes. 

However, the IOC contested the jurisdiction of CAS Ad Hoc Division panel on the basis that: 

• a duly executed entry form is required to invoke arbitration authority and this was not provided; 
• Clunis did not list a specific decision to be challenged in the CAS Ad Hoc Division; and  
• the dispute arose outside of the required 10 days preceding the Olympic Games.   

World Athletics opposed the application and noted the athlete selected for Paris 2024 in place of Clunis would be penalised due to the omission by JAAA. 

Decision 

Article 1 of the Rules provides that for the CAS Ad Hoc Division to have jurisdiction the relevant dispute must arise during the Olympic Games or a period of 10 days preceding the Opening Ceremony of the Olympic Games. 

Clunis submitted the date of the dispute was 19 July 2024, being the date World Athletics’ submissions were provided which formally rejected her inclusion in the Games. 

The Panel held that the dispute arose either when Clunis became aware that her name had not been included on the list submitted by JAAA to World Athletics, or when she first became aware that the mistake would not, or could not, be rectified by World Athletics. In either case, both dates fell outside the 10 days prior to the Opening Ceremony of Paris 2024. 

As a result, the Panel concluded it had no jurisdiction as the dispute arose before the period of 10 days preceding the Opening Ceremony of Paris 2024. 

Outcome 

Application unsuccessful – the CAS Ad Hoc Division did not have jurisdiction to hear the application. 

Mahmoud Al Hamid v. International Weightlifting Federation^[5]

Facts  

Mahmoud Al Hamid (Al Hamid) is a Saudi weightlifter and member of the International Weightlifting Federation (IWF).  

On 25 November 2023, the Saudi Doping Control Committee took a urine sample from Al Hamid. This sample resulted in a positive test being returned, indicating the presence of erythropoietin, a prohibited substance. On 21 January 2024, a provisional suspension was imposed on Al Hamid.  

Following a request by Al Hamid, an additional sample was analysed in March 2024. This test returned a negative result and Al Hamid’s provisional suspension was lifted.  

On 10 May 2024, Al Hamid filed an Application for Exemption to Compete in Paris 2024 with the IWF. Al Hamid submitted that, due to his provisional suspension, he had not been able to participate in two qualifying events, preventing him from meeting the qualification criteria for Paris 2024. IWF rejected Al Hamid’s application by letter, stating that while an athlete may file for exemption if they are unable to participate in a compulsory qualification event, the exemption must be filed within five days of the relevant competition occurring. Al Hamid had not filed his application within this timeframe and his exemption request was not accepted by IWF.  

On 22 July 2024, Al Hamid filed an application with the CAS Ad Hoc Division and submitted:  

• the positive test result was a mistake and the provisional suspension resulting from that test result had prevented Al Hamid from participating in sporting events that were mandatory for qualification for Paris 2024;  
• article 1.3 of the IWF Qualification System allows for exemptions based on exceptional circumstances; and  
• although the appealed decision of the IWF predates the requirements under Article 1 to invoke the jurisdiction of the CAS Ad Hoc Division, the ongoing impact of the decision extends into the required timeframe, and therefore the CAS Ad Hoc Division had jurisdiction.  

Decision  

Article 1 of the Rules provides the relevant dispute must arise during the Olympic Games or during a period of 10 days preceding the Opening Ceremony of the Olympic Games to invoke jurisdiction in the CAS AD Hoc Division.  

The Panel determined the date of dispute as 24 May 2024, being the date Al Hamid was informed that the IWF had determined the application for exemption could not be accepted. 

The Panel held it had no jurisdiction as the dispute arose prior to a period of 10 days preceding the Opening Ceremony of the Paris Olympic Games.  

Outcome 

Application unsuccessful – the CAS Ad Hoc Division did not have jurisdiction to hear the application. 

David Sánchez López v. Turkish Weightlifting Federation^[6]

Facts

On 6 May 2024, the Turkish Weightlifting Federation (TWF) was notified that the Independent Member Federations Sanctioning Panel (Independent Panel) had commenced disciplinary proceedings against it due to anti-doping violations involving three Turkish athletes in April and May 2023. 

The TWF was charged with violation of Article 12.3.2 of the IWF’s 2024 Anti-Doping Rules (Rules) and Section C lit. b of the IWF Qualification System (OQS). Article 12.3.2 states that if three or more anti-doping violations are committed by athletes or persons affiliated with an International Weightlifting Federation (IWF) member federation within a 12-month period, the Independent Panel can impose consequences on the member federation. The specific consequences that may be imposed ‘shall be determined by the Independent Panel at its discretion’.

On 21 June 2024, the IWF published its Olympic Qualification Ranking lists for each weight class to be contested at Paris 2024, which stated only athletes ranked in the top 10 would be allocated an Olympic place. Sanchez López (López) is a Spanish weightlifter and was ranked eleventh in the 73kg class.

On 5 July 2024, the Independent Panel issued its decision regarding the anti-doping violations of the three Turkish athletes. Under Article 12.3.2, the Independent Panel ‘deem[ed] it fair and proportionate to impose a fine of $100,000 against the TWF for violation of Rules Art. 12.3.2’.

On 8 July 2024, the weightlifting entries for Paris 2024 were published and included a Turkish weightlifter in the 73kg weight class.

The Independent Panel found the OQS requirement of automatic withdrawal of all quota places at Paris 2024 was not applicable, because the underlying violations did not involve periods of ineligibility of four years or more. Additionally, the Independent Panel held ‘it would be disproportionate to order the withdrawal of the single Olympic quota place earned by Turkish weightlifters’.

On 2 August 2024, López appealed the Decision with the CAS Ad Hoc Division. López submitted that:

• under the IWF’s Anti-Doping Rules, upon the IWF’s finding of three anti-doping violations by persons affiliated with the TWF, the IWF was obligated to bar the TWF and all its affiliated athletes from competing in Paris 2024; and 
• he should replace the TWF’s entry in the 73kg weight class.

Decision

Article 1 of the Rules provides all applications must arise during the Olympic Games or during a period of 10 days preceding the Opening Ceremony of the Olympic Games. Although the Independent Panel’s decision was rendered on 5 July 2024, it was not made publicly available until 22 July 2024. The Panel therefore found the dispute arose within the 10 days prior to Paris 2024.

According to CAS jurisprudence, an applicant must have a protectable interest or legitimate interest in the challenged decision. This requirement will be met if the applicant is sufficiently affected by the impugned decision and a concrete interest of a financial or sporting nature is at stake.

The Panel held it was insufficient that the decision not to bar Turkish weightlifters from Paris 2024 meant López could not compete. Article 13.2.3 of the relevant rules provides that persons entitled to appeal decisions imposing sanctions for antidoping rules violations include:

• the athlete or person who is the subject of the decision; 
• the other party;
• the National Anti-Doping Organisation of the person’s country of residence; 
• the International Olympic Committee; and 
• WADA.

The Panel noted López did not fall within one of these categories.

Alternatively, Article 13.2.3.5 of the Rules provides that appeals from decisions rendered under Article 12 may be appealed to CAS ‘by the Member Federation or other party.’ While ‘other party’ is not defined, its use elsewhere in the Rules suggests it does not include persons outside of the underlying proceeding.

The Panel found López lacked standing as he was not one of the specified persons entitled to appeal the relevant decision and was not a participant in that proceeding who was directly affected by the decision.

The Panel found that as López lacked standing, it was not required to assess the merits of his claims against the relevant decision. In any event, the Panel noted that Anti-Doping Rules Article 12.3 is explicitly discretionary and the relevant decision was not an abuse of its discretion or unreasonable.  

Outcome

Application unsuccessful – the Turkish weightlifter was allowed to compete and López was not included as his replacement.

Israel Football Association & Mr. Roy Revivo v. Fédération Internationale de Football Association (FIFA)^[7] 

Facts 

On 21 March 2024, Roy Revivo (Revivo), a member of the Israeli Olympic football team, received a red card in a football match between Israel and Iceland during the UEFA Euro 2024 Qualifiers.

On 23 April 2024, the UEFA Control, Ethics and Disciplinary Body (CEDB) imposed a two-match suspension on Revivo (CEDB Decision), which was not appealed. 

On 16 July 2024, UEFA informed FIFA, the international football governing body, that Revivo’s suspension would be served for the first two Israeli matches in Paris 2024.  

On 22 July 2024, the Israeli Football Association (IFA) filed a protest against this decision. On the same day, the FIFA Disciplinary Committee dismissed the appeal (Appealed Decision), on the basis that: 

• under the UEFA Disciplinary Regulations, if a suspension is not served in the competition where the offence was committed, it shall be automatically carried forward to the next UEFA competition, or an equivalent age category FIFA World Cup or Olympic tournament. Revivo had not served any of the match suspensions, and was required to serve his suspension in the upcoming matches of the Israel national team in Paris 2024; and 
• the protest was not lodged in accordance with relevant rules, which require that protests regarding player eligibility must be filed by five days before the first match.  

On 23 July 2024, Revivo and the IFA filed an application with the CAS Ad Hoc Division and submitted:

• the Appealed Decision disregarded the CEDB Decision and relied on the UEFA Disciplinary Regulations; 
• FIFA was unauthorised in interpreting the punishment more broadly than the CEDB Decision; and  
• the urgent nature of the matter precluded the exhaustion of FIFA’s internal remedies.

Decision           

Under Article 1 of the Rules, an applicant must first exhaust all internal remedies available under the regulations of the relevant sports body before a CAS Ad Hoc Division Panel can have jurisdiction to hear an application. In this instance, the Panel considered IFA and Revivo should have initially challenged the Appealed Decision to the FIFA Appeal Committee, since it considered the Appealed Decision fell within the jurisdiction of that Committee. However, given the Appealed Decision was issued only two days before Israel’s first match of Paris 2024, the Panel was satisfied the time needed to first exhaust internal remedies would make the appeal to the CAS Ad Hoc Division ineffective and agreed to hear the dispute due to the urgency. 

IFA and Revivo filed the protest on 22 July 2024. The Panel noted the first Paris 2024 match for the Israeli team was scheduled for 24 July 2024, meaning the deadline to lodge a protest under the relevant rules was 19 July 2024 (five days before the first match). Consequently, the Panel accepted the FIFA Disciplinary Committee’s Appeal Decision, which ruled the protest inadmissible because it was lodged outside of the specified timeframe. 

Outcome 

Application unsuccessful – Revivo was ineligible to play the first two matches of Paris 2024.  

Marta Vieira da Silva, Comitê Olímpico do Brasil (COB) & Confederação Brasileira de Futebol (CBF) v. FIFA^[8]

Facts

On 31 July 2024, a football match was played between Brazil and Spain at Paris 2024. During the match, Brazilian player Marta Vieira da Silva (Marta) was sent off following an incident.

The referee and match commissioner both indicated in their separate reports that Marta was sent off for serious foul play. The referee noted in his report that the incident involved Marta endangering the safety of her opponent during a tackle. 

On 1 August 2024, the Secretariat of the FIFA Disciplinary Committee informed Marta and the Comitê Olímpico do Brasil (COB) the incident constituted a breach of Article 14.1(e) of the FIFA Disciplinary Code (Code). The proposed sanction was a two-match suspension for Marta. The Confederação Brasileira de Futebol (CBF) rejected the proposed sanction, and the matter was referred to the FIFA Disciplinary Committee. 

On 2 August 2024, the FIFA Disciplinary Committee upheld the two-match suspension, which Marta was to serve during the France v Brazil match on 3 August 2024 at Paris 2024 and the next official match of the Brazilian team.

On 5 August 2024, Marta, COB and CBF (Applicants) filed an application with the CAS Ad Hoc Division. The Applicants submitted that: 

• the incident did not fall under Article 14.1(e) of the Code as it did not amount to serious foul play. Rather, the incident should be categorised as ‘unsporting behaviour’; and 
• the relevant article to be applied to the incident was Article 14.1(b) of the Code and therefore the suspension should be reduced to one match and Marta authorised to participate in Brazil’s semi-final match against Spain on 6 August 2024. 

Decision

Article 50.3(b) of the FIFA Statutes provide that CAS will not deal with appeals arising from ‘suspensions of up to four matches or up to three months’. The Applicants asserted they were not challenging the two-match suspension, but rather challenging the underlying determination of the applicability of Rule 14.1(e) of the Code. However, the CAS arbitrator held that in challenging the applicability of the Code, the natural consequence was to challenge the two-match suspension and this nexus could not be separated. Consequently, the arbitrator held the application must be dismissed as the suspension of Marta was for less than five matches and not within the jurisdiction of CAS to review. 

Outcome

Application unsuccessful – Marta’s two-match suspension was upheld, and she was unable to compete in Brazil’s semi-final match against Spain on 6 August 2024.

Qualification and selection disputes

Participating in the Olympic Games is often the peak of an athlete’s career and the result of many years of hard work and dedication. However, participation in the Olympic Games is a privilege and rule 44.3 of the Olympic Charter provides: 

‘Nobody is entitled to any right of any kind to participate in the Olympic Games.’

To be selected to participate at an Olympic Games, athletes must meet a number of criteria. Athletes who satisfy the applicable citizenship criteria for a country may be nominated by their national Olympic association (NOC) to the International Olympic Committee (IOC) to participate in the Olympic Games. This nomination generally follows a recommendation by the national federations (NF) for the relevant sport and after consideration of the qualification criteria for the relevant events determined by the international federation (IF) for that sport.

Most disputes regarding qualification and selection are resolved in advance of the Olympic Games. Those disputes may also be heard by CAS’s ‘ordinary’ tribunal. However, in some instances, qualification and selection disputes can be unresolved in the immediate lead up to the Olympic Games and result in applications to the CAS Ad Hoc Division.

Cook Islands Aquatics Federation and Cook Islands Sports and National Olympic Committee v. World Aquatics^[9]

Facts 

Wesley Tikiairki Roberts (Roberts) is a swimmer. Roberts represented the Cook Islands at the Olympic Games in 2016 and 2020. 

At each Olympic Games the IOC makes positions available for athletes from underrepresented NOCs. These Universality Places are intended to increase the diversity of participating nations across the sports program of the Olympic Games, and are available in the qualification systems of select sports for nations with traditionally small delegations.^[10] Applications for Universality Places were required to be submitted to World Aquatics by 24 June 2024. On 5 May 2024, ahead of this deadline and in response to a query from Cook Islands Aquatics Federation (CIAF), World Aquatics notified CIAF that Roberts’ participation in two prior Olympic Games made him ineligible for a Universality Place at Paris 2024. 

World Aquatics and Cook Islands Sports and National Olympic Committee (CISNOC) engaged in discussions throughout late May and early June 2024, with CISNOC continuing to request an exemption for Roberts. World Aquatics continued to reject the exemption request on the basis that Roberts did not meet the Universality Placing criteria. 

On 3 July 2024, World Aquatics wrote to CISNOC referring to D.3 of its Qualification System rules, which it said meant athletes will be ineligible for Universality Places if they had either competed in two or more Olympic Games or are older than 30 years as of 1 January 2025. 

After further failed attempts to convince World Aquatics, CIAF and CISNOC filed an application with the CAS Ad Hoc Division on 21 July 2024. 

CIAF and CISNOC submitted to the panel: 

• the CAS Ad Hoc Division had jurisdiction to hear the appeal;
• articles C.2 and D.3 of the Qualification System rules provided two alternative ‘gates’ through which an athlete may qualify for a Universality Place, that is, as long as an athlete: (a) has not competed in more than one Olympic Games, or (b) is no more than 30 years old on 1 January 2025, he or she was eligible for a Universality Place;
• as Roberts will be under 30 years old on 1 January 2025, he was eligible for Universality Placement, despite his participation in two prior Olympic Games;
• if the appeal was unsuccessful, there would be no universality athlete in a swimming event from the Cook Islands at Paris 2024, which was contrary to the IOC Qualification System Principles; and
• any ambiguity in articles C.2 or D.3 should be interpreted against World Aquatics. 

Decision 

In rejecting the CIAF and CISNOC application, the Panel noted that while World Aquatics had told CIAF and CISNOC as early as 5 May 2024 that Roberts would be ineligible for Universality Placing, the matter still fell within the 10-day window. The Panel rejected the submission of the IOC that the dispute arose no later than 3 July 2024 (when World Aquatics invited the Applicants to ‘file a challenge’), ruling that World Aquatics’ acceptance of that challenge on 18 July 2024 brought the dispute within the 10-day window and the jurisdiction of the Panel. 

The Panel held World Aquatics’ interpretation of the qualification standards was correct, in that they were expressly ‘limiting’ standards rather than qualification or eligibility standards. The Panel held that the correct interpretation of the relevant rule is that an athlete cannot qualify for Universality Placing if they had competed in more than one Olympic Games ‘or’ are more than 30 years old on 1 January 2025. 

Outcome 

Application unsuccessful – the Panel dismissed the application – Roberts was not able to participate at Paris 2024.

Livia Avancini v. World Athletics^[11], Max Batista v. World Athletics^[12], Hygor Bezerra v. World Athletics^[13]

Facts

This consolidated case concerned eligibility disputes involving three Brazilian athletes, Lívia Avancini (shot put), Max Batista (race walker) and Hygor Bezerra (sprinter). 

World Athletics’ Athletics Integrity Unit (AIU) declared the athletes ineligible to compete at Paris 2024 due to a failure to meet certain anti-doping requirements. World Athletics had imposed additional testing requirements on the Brazilian Athletics Federation (Additional Testing Requirements). The Additional Testing Requirements, which related to athletes who were not part of the AIU’s Registered Testing Pool, stated that other than in truly exceptional circumstances, no Brazilian athlete may participate at Paris 2024 unless they had undergone at least three no notice out-of-competition tests (urine and blood). 

Testing in Brazil is conducted by a government agency, the Autoridade Brasileira de Controle de Dopagem (ABCD). Following the imposition of the Additional Testing Requirements, the ABCD began testing athletes based on its understanding that the Additional Testing Requirements mandated at least three out-of-competition tests of urine and of blood, that is, six tests for each athlete. 

In the three-month period available, over 470 anti-doping tests were carried out by the ABCD on Brazilian athletes to comply with the Additional Testing Requirements and facilitate the athletes’ participation in Paris 2024. The only athletes selected for Paris 2024 for whom there was insufficient testing were the three athletes.   

Both the Brazilian Athletics Federation and each of the three athletes made applications to World Athletics applying for an exception to the Additional Testing Requirements due to exceptional circumstances. The applications were all denied by World Athletics on the basis there were no truly exceptional circumstances which prevented compliance with the Additional Testing Requirements.

The athletes challenged the decision they were ineligible for Paris 2024 and sought an order to be allowed to compete. The athletes submitted to the CAS Ad Hoc Division Panel: 

• the wording of the Additional Testing Requirements were reasonably construed by ABCD as requiring both urine and blood samples, that is, six tests for each athlete. This interpretation imposed significant pressure on the resources of, and additional cost to, ABCD; 
• further funding for ABCD to undertake the tests could not be secured as the yearly budget had been set by the Brazilian Government before the imposition of the Additional Testing Requirements and ABCD is the only testing authority permitted to carry out the testing in Brazil; 
• there was no suggestion the Athletes were not ‘clean’ athletes; and
• as a result, the Athletes should be excepted from the Additional Testing Requirements due to the ‘truly exceptional circumstances’.

Decision 

The CAS Ad Hoc Division Panel accepted the interpretation by ABCD that six tests were required for each athlete, rather than three, was the key reason why full testing was not carried out on the athletes within the required period. The Panel also accepted this interpretation by ABCD was reasonably open and that substantial efforts were made to conduct six test per athlete within the Brazilian Government budget during the short period available for implementation. 

The Panel considered that truly exceptional circumstances existed in this instance due to the (reasonable) interpretation of the Additional Testing Requirements by the ABCD, the timing of the Additional Testing Requirements being imposed and the resourcing issues of ABCD. 

Outcome

Application successful – the panel set aside the decision of World Athletics and the three athletes  were entitled to participate at Paris 2024.

Jitka Čábelická v. Czech Cycling Federation & Czech Olympic Committee^[14] 

Facts

Jitka Cabelicka (Cabelicka) is a Czech professional cross-country mountain bike cyclist. 

Cabelicka sought to qualify for Paris 2024 based on nomination criteria published on the Czech Cycling Federation (CCF) website on 1 November 2023. The Nomination Criteria appeared to place a cascading level of importance on performances at World Cup, European Championship and Czech Cup races, with greater weighting placed on higher finishes and elite (as opposed to under 23) races. 

After various races in April and May 2024, the National Team Coach circulated an email stating that as Cabelicka, Adéla Holubová (Holubová) and a third cyclist were all under consideration for Paris 2024, the Czech Cup on 8 June 2024 would be used as an effective tie-breaker to determine who would be nominated to participate in Paris 2024. 

At the Czech Cup Holubová finished first while Cabelicka did not finish due to a technical problem.  On 9 June 2024 the National Team Coach circulated an email declaring that Holubová was the final nomination for the Paris 2024 team while Cabelicka was first reserve. 

On 10 June 2024 Cabelicka made a request to the Czech Olympic Committee (COC) Ombudsman to investigate compliance by the CCF with the selection criteria. The COC did not accede to Cabelicka’s request to revisit the approval of Holubová. Discussions continued between the parties until 17 July 2024, when the COC Ombudsman emailed Cabelicka stating that ‘the decisions of these bodies [were] final and closed’. On 23 July 2024, Cabelicka filed an application with the CAS Ad Hoc Division.

Cabelicka submitted to the Panel: 

• there were concerns as to the objectivity of the Coaches Committee in the nomination process;
• her preparation was based on the nomination criteria published on 1 November 2023 and that prior to these being changed, she was the only female Czech athlete fulfilling the criteria;
• modifications made to the nomination criteria by the National Team Coach by email on 29 May 2024 were unjustified and irrational (as it placed performance in a single low-ranked event above long-term performance) and violated the principle of legal certainty; and 
• notwithstanding the late changes made to the nomination criteria, the selectors’ assessment of Cabelicka’s race day performances (in comparison with Holubová) against the new criteria was incorrect and unsubstantiated. 

Decision 

The Panel held it had jurisdiction to hear the application.   

In rejecting Cabelicka’s application, the Panel noted CAS and CAS Ad Hoc Division case law which establishes that the discretion granted to national federations in making Olympic selections is ‘broad and deep’. However, a national federation still has a legal duty ‘not to be arbitrary, unfair or unreasonable in the application of objective selection criteria’. 

The Panel considered the nomination criteria of 1 November 2023 and the further nomination criteria published in the email of 29 May 2024 emphasised a ‘comprehensive assessment’. The Panel found the selectors only appeared to have altered the criteria on 29 May 2024 because their ‘comprehensive assessment’ of Cabelicka and Holubová’s previous results led them to believe a tie was imminent (based on the 1 November 2023 nomination criteria). The Panel did not find the nomination criteria had been amended in an unfair or biased way. Further, the Panel was not convinced of any bias or bad faith on the part of one of the coaches in the Coaches Committee, notwithstanding that he was also Holubová’s coach. 

Outcome 

Application unsuccessful – the Panel dismissed the application and Cabelicka was not able to participate at Paris 2024. 

Dany Brand v. World Athletics^[15]

Facts

Dany Brand (Brand) is a Swiss athlete specialising in the men’s 400m hurdles. 

On 20 December 2022, World Athletics published its Qualification System for Paris 2024. According to the Qualification System, 40 entries were available in the men’s 400m hurdles. The Qualification System for the 400m hurdles provided that qualification could be achieved either by meeting an entry standard (time based) or, if not all quota places were filled by athletes meeting the time-based entry standard, by allocation on the basis of the World Athletics World Rankings within the relevant ranking period.

On 2 July 2024, the list of entries for Paris 2024 was published by World Athletics. 37 athletes had met the time-based entry standard, and an additional three athletes – numbers 38-40 on the World Athletics World ranking – were included in the list of qualified athletes. Brand was ranked number 41 and therefore the first athlete to miss being included in the entry list.

On 6 July 2024, Swiss Athletics (SA) wrote to World Athletics, pointing out that although no places had been declined, a French athlete, Ludvy Vaillant (Vaillant) and a Brazilian athlete were likely not to compete at Paris 2024 due to injuries, and that Brand should be entered in the men’s 400m hurdles.

By email of 8 July 2024, World Athletics advised SA that it had contacted the French and Brazilian national federations, and they had confirmed their athletes were going to compete at Paris 2024.  

Vaillant was entered in the 400m hurdles at Paris 2024 by the French NOC on the internal condition that he would pass a ‘competitivity test’ by 21 July 2024 set by the French Athletic Federation as he was recovering from an injury. Vaillant failed the test and was withdrawn from the entry list on 22 July 2024.

On 27 July 2024, based on the fact that only 39 of the 40 quota places were filled, SA asked World Athletics to review Brand’s situation. 

On 28 July 2024, World Athletics responded to SA stating the French Athletics Federation was entitled to select Vaillant based on the qualification criteria and the decision was not a matter for World Athletics. World Athletics suggested SA’s NOC contact the IOC directly with any further concerns or queries. Swiss Olympic contacted the IOC a number of times in late July and early August about SA’s request, but did not receive a reply from the IOC.

On 2 August 2024, Brand filed an application with the CAS Ad Hoc Division. Brand submitted to the Panel: 

• according to Rule 44, para. 5, of the Olympic Charter, the NOCs shall send to the Olympic Games only those competitors adequately prepared for high-level international competition. This requirement must be met at the time when an athlete is entered for the Olympic Games by its NOC  Vaillant did not meet the requirements of this rule at the time he was entered in the Olympic Games by the French NOC, which is why the entry of Valliant should be considered invalid;
• instead of Vaillant, Brand should have been accepted as an entry for Paris 2024 as the next ranked athlete in the World Ranking;
• by allowing Brand to fill the place, no other person would be disadvantaged; and 
• such reallocation of places had been made by other international federations, such as the international federation for wrestling, as late as 29 July 2024.

Decision 

The Panel held Brand had no right to be entered in the 400m hurdles, and no basis for his claim. The Panel noted World Athletics was correct in not forwarding SA’s request to the IOC Executive Board for review, that entries fall within the discretion of NOCs (under Rule 44 of the Olympic Charter) and only in circumstances of clear abuse should a decision about who is included in an entry list be submitted for review. The Panel considered the French NOC’s decision to enter Vaillant and to give him a chance to prove he was adequately prepared to compete was not arbitrary or unreasonable.

In dismissing the application, the Panel emphasised that athletes do not have a right to participate in the Olympic Games and the right to enter an athlete (or not) lies with the NOCs. 

Outcome

Application unsuccessful – the Panel dismissed the application – Brand was not able to participate at Paris 2024.

Field of play disputes

The application and interpretation by umpires, referees and officials of the rules that govern sporting competitions are known as ‘field of play’ decisions. These decisions can include pure sporting decisions, such as determining whether a foul is committed, or more technical applications, such as appeal procedures. For policy reasons, field of play decisions are generally not reviewable in a tribunal such as CAS after the conclusion of an event, unless the decision was fraudulent, biased or made in bad faith. 

Italian Swimming Federation v. World Aquatics^[16] 

Facts 

On 7 August 2024, Italy and Hungary played in the Paris 2024 men’s water polo quarter final. 

With 2 minutes and 22 seconds remaining in the second quarter, Italian player Francesco Condemi (Condemi) scored a goal; however, in the process, his throwing hand struck a Hungarian player in the face. The two referees consulted video review technology and ruled Condemi had committed a ‘violent action’ under Part Six, Article 9.14 of the World Aquatics Competition Regulations (Regulations). The goal was disallowed and Condemi was excluded from the remainder of the game.

Hungary won the game 12-10 in a penalty shootout after regular time ended in a tied score. Immediately after the game, the Italian team leader filed a protest under the Regulations, asserting that Condemi innocently and accidentally struck the Hungarian player in his follow-through. The Italian team argued the game should be replayed entirely or from the moment of Condemi’s exclusion. The referees rejected the protest. 

The Italian team subsequently appealed the referee’s decision to the World Aquatics Jury of Appeal under Part One, Article 13.2 of the Regulations. 

In a separate proceeding, World Aquatics’ Management Committee for Water Polo at the Olympic Games (Management Committee) considered whether Condemi’s actions warranted exclusion from additional games, based on the Regulations. On 8 August 2024, the Management Committee found that Condemi would not be excluded from additional games as it could not conclude that there was a malicious intent. 

On the same day, the World Aquatics Jury of Appeal denied the appeal in relation to the referee’s decision as it could not find that the referees had acted irrationally, arbitrarily or in abuse of their discretion.  

On 9 August 2024, the Italian Swimming Federation (ISF) filed an application with the CAS Ad Hoc Division. ISF submitted: 

• it was significant the Jury of Appeal had recognised Condemi’s lack of intent; 
• the referees’ decision was arbitrary, irrational and abusive, as evidenced by the Management Committee’s decision not to impose additional games of exclusion on Condemi; and 
• the sanctions against Condemi should be cancelled, as should the result of the game, and the game should be replayed, with 2 minutes and 22 seconds remaining in the second quarter. 

Decision 

In rejecting ISF’s application, the Panel noted this was a situation where it must apply the field of play doctrine, meaning there were only limited circumstances where decisions made by game officials during a match could be appealed. The Panel recognised the doctrine from previous CAS cases regarding the field of play that a referee’s decision affecting the result of a race or game cannot be reviewed on appeal without proof of bias, malice, bad faith, arbitrariness or legal error. 

There was no evidence presented to the Panel that any of the individuals involved in the decision were tainted by bias, malice or bad faith against Condemi or the Italian team. 

Outcome 

Application unsuccessful – the Panel dismissed the application.

Federation Romanian Gymnastics and Ana Maria Barbosu v. Donatella Sacchi and Federation Internationale de Gymnastique (FIG)^[17]; Federation Romanian Gymnastics and Sabrina Malenca-Voinea v. Donatella Sacchi and Federation Internationale de Gymnastique (FIG)^[18]

Facts

On 5 August 2024 the women’s floor exercise final in artistic gymnastics was held at Paris 2024. 

The athletes in the final included Romanian gymnasts Ana Maria Barbosu (Barbosu) and Sabrina Malenca-Voinea (Malenca-Voinea) and USA gymnast Jordan Chiles (Chiles).

The scores for an artistic gymnastics floor exercise routine comprise a difficulty score and an execution score.

Barbosu was awarded a total score of 13.700 for her routine. 

Malenca-Voinea was awarded a total score of 13.700, following deduction of a penalty of 0.1 for allegedly stepping outside the boundary during her routine.

Chiles was awarded a total score of 13.666, comprising a difficulty score of 5.8 and an execution score of 7.866. 

Following the publication of Chiles’ score her coach submitted an inquiry to the FIG official in relation to the difficulty score given to Chiles’ routine by the judges (Chiles inquiry). The purpose of the Chiles inquiry was to obtain a re-assessment of the difficulty score given to her routine. Following review of the Chiles inquiry, the difficulty score for Chiles’ routine was revised to 5.90 and therefore Chiles’ total score was increased to 13.766.

The results on the day of the final were: Chiles was third (13.766), Barbosu was fourth (13.7) and Malenca-Voinea was fifth (13.7). The medals were presented on the day of the event, with Chiles being awarded the bronze medal.

On 6 August 2024 the Romanian national gymnastics federation – Federation Romanian Gymnastics – commenced proceedings in the CAS Ad Hoc Division. The proceedings essentially related to the following:

• an application that the Chiles inquiry should have been dismissed as it was:
  • made out of time under the relevant FIG regulations; and
  • conducted in bad faith; and
• Malenca-Voinea should not have been given a 0.1 penalty as she was unable to make a challenge in relation to that penalty at the time and that she did not in fact contravene the rule by stepping outside the boundary.

The effect of each of the applications would impact the results on the day of the event as follows:

• dismissing the Chiles inquiry would result in Chiles’ total score being 13.666 and therefore Chiles would not finish third; and
• removing the penalty imposed on Malenca-Voinea would increase the score for her routine to 13.8 and therefore she would finish above Barbosu and Chiles.

The respondents to the application were the relevant FIG official, Donatella Sacchi (Sacchi), and FIG.  Various other parties, including Chiles, USA Gymnastics, the United States Olympic & Paralympic Committee and the IOC, were given the opportunity to participate in the hearing as interested parties. 

Decision – Chiles inquiry

Article 8.5 of FIG Technical Regulations 2024 provides for a time window of one (1) minute after the score is shown on the scoreboard in which to lodge an inquiry about the score.

The evidence before CAS was the inquiry about Chiles’ difficulty score had been lodged shortly after the one-minute deadline.

At the CAS hearing Saachi said she had proceeded on the basis the inquiry had been submitted within the one-minute time window. There was evidence during the hearing that there was not a proper system in place for monitoring the timeliness of when an inquiry had been lodged. Sacchi said if she had known that Chiles’ inquiry was made outside the one-minute requirement then she would not have proceeded to conduct the inquiry and would have consulted with her supervisor.

FIG said although the technical regulations referred to a one-minute timeline, the regulation should be read as allowing some tolerance. FIG was unable to refer to a legal basis for this assertion. In rejecting the argument there was any degree of tolerance in the one-minute timeline, the Panel found the one-minute rule was a clear, fixed and unambiguous deadline that offered no flexibility. The Panel stated there was no evidence or practice to support FIG’s claim that the rule should be exercised with tolerance.

FIG asserted the challenge to the Chiles inquiry should fail as a challenge to the decision of a gymnastics judge about a difficulty score was covered by the field of play doctrine, and that in the absence of bad faith or fraud, the Panel could not overturn the decision of the gymnastics judge. USA Gymnastics and Chiles supported FIG’s submissions about the field of play doctrine, noting that the doctrine constitutes ‘a bedrock principle of sports law’. 

The Panel found the challenge to the Chiles inquiry did not fall within the field of play doctrine because it was not being asked to interfere with a judgment call made during competition. The Panel said there was ‘a manifest default’ as FIG did not have in place arrangements or mechanisms to ensure the one-minute requirement was complied with to monitor the application of an important rule. The Panel found the Chiles inquiry had proceeded on the basis the inquiry was within time, and the Chiles inquiry should not have occurred because the inquiry had been lodged outside the time permitted by the rules. The Panel said the gymnastics judges and athletes had been ‘let down by the absence of effective arrangements on the timing of inquiries’.   

The Panel found it had no alternative but to find the one-minute rule was not complied with, and therefore the Chiles inquiry was out of time. 

The Panel went on to say it was not necessary to consider whether the gymnastics judge had acted in bad faith but noted if it had to make a finding on that issue, it would not have found there was any bad faith by the gymnastics judge in this instance.

The Panel upheld the application in relation to the Chiles inquiry. This meant the Chiles inquiry was dismissed, and Barbosu was awarded third place in the women’s artistic gymnastics floor exercise final (in place of Chiles).

Decision – Malenca-Voinea penalty

The Panel found the decision of the gymnastics judges to deduct 0.1 from Malenca-Voinea score was a ‘textbook’ field of play decision. As such, the decision was not challengeable before the Panel. 

The Panel noted that Malenca-Voinea had a right to challenge the penalty on the day of the competition under the FIG rules but had not done so. Malenca-Voinea’s failure to exercise that right of review meant she was precluded from a later challenge before CAS. Further, the Panel found there was no evidence of fraud, bias or arbitrariness in the decision to impose the penalty.

Malenca-Voinea’s application was dismissed.

Outcome

Application in relation to the Chiles inquiry was successful – Chiles’ inquiry after the floor exercise final was found to be made out of time and therefore invalid – the increase to Chiles’ score was revoked – Chiles’ third place finish was changed to a fifth place finish.

Application by Malenca-Voinea unsuccessful – Malenca-Voinea’s score was not adjusted.

Benjamin Savšek & OCSASF v. International Canoe Federation^[19]

Facts

On 29 July 2024, Benjamin Savšek (Savšek) competed in the Men’s Canoe Slalom C1 Final in Paris 2024.

At gate 5 of the course, Savšek hit the post, resulting in two of the gate judges calling a 50-second penalty, and two other gate judges calling a 2-second penalty. Based on the discrepancy between the judges, the situation was reviewed by the chief judge who was the final arbiter on all judging matters under the ICF Canoe Slalom Competition Rules 2023-2024 (Competition Rules).

The chief judge agreed with the imposition of a 50-second penalty and Savšek’s time was set at 144.93 seconds instead of 96.93 seconds. The 50-second penalty resulted in Savšek finishing in 11^th place rather than 3^rd place.    

On 3 August 2024, the Olympic Committee of Slovenia Association of Sports Federations (OCSASF) requested an official explanation of the judges’ decisions. On 4 August 2024, the International Canoe Federation (ICF) clarified its decision to OCSASF and confirmed that under Article 11.1.9 of the Competition Rules, once the enquiry process is complete, the result is final and cannot be protested further. 

On 9 August 2024, Savšek and OCSASF filed an application with the CAS Ad hoc Division.

Savšek and OCSASF submitted that:

• the chief judge erroneously amended the 2-second penalty to a 50-second penalty with no explanation;
• Savšek should have been given the benefit of the doubt as to whether he hit the post at gate 5 under Article 10.3 of the Competition Rules;
• the application falls under an exception to the field of play doctrine, as it involves the review of the interpretation of Competition Rules by the chief judge against the measures of fairness and non-arbitrariness; and
• there was no explanation or official report that detailed the reasons for the changed penalty.

Decision

Under the field of play doctrine, CAS cannot review official decisions made in the course of sporting competitions. The rationale for this field of play doctrine is that CAS arbitrators are not sufficiently trained in the rules of any or all sports and do not observe the event. 

Exceptions to the field of play doctrine exist where there is sufficient proof of bias, bad faith, arbitrariness or a legal error. However, the arbitrator found Savšek and OCSASF had failed to adequately discharge the burden of proof required to establish that the decision of the chief judge was rendered in violation of principles of fairness and non-arbitrariness.

Further, the arbitrator determined the lack of explanation for the chief judge’s decision and lack of opportunity to appeal the decision was consistent with applicable policy rules and regulations. Consequently, the arbitrator was not in a position to deal with the reasons behind these rules or substitute them. 

Outcome

Application unsuccessful – the imposition of the 50-second penalty was upheld. 

Vinesh Phogat v. United World Wrestling & IOC^[20]

Facts

Vinesh Phogat (Phogat) is an Indian wrestler who was due to compete in the gold medal bout of the 50kg Freestyle division on 7 August at Paris 2024.

On the morning of 7 August 2024, Phogat weighed in at 150g over the 50kg limit. When Phogat weighed in again 15 minutes later (as is permitted by United World Wrestling International Wrestling Rules 2023 (Rules)) she was 100g over the limit. As a result, Phogat received a disqualification letter under Article 11 of the Rules, due to exceeding the required weight limit. 

That afternoon, Phogat filed an application with the CAS Ad Hoc Division. Two of her requests for relief were to be eligible and qualified to participate in the gold medal bout, and to be re-weighed before the gold medal bout. The Sole Arbitrator was not appointed until the next day, after the gold medal bout had taken place and medals had been awarded, and Phogat subsequently withdrew her two requests for relief.

Instead, Phogat submitted to the CAS Panel:

• she had failed the weigh-in because she needed to eat and drink for her health after difficult preliminary competitions and that being pre-menstrual had caused her to retain fluid;
• the scales were somehow faulty or not calibrated correctly;
• there was insufficient training of, and explanation to, athletes from diverse backgrounds and levels of understanding of the procedures;
• the Olympics are an ‘International Tournament’ for the purposes of Article 8 of the Rules, which provides that a ‘2kg weigh tolerance is allowed for World Cup, UWW Ranking Series Tournaments and for International Tournaments’;
• the consequence of Article 11 that an athlete who does not attend or fails a weigh-in will be eliminated from the competition and ranked last is inequitable and too severe; and
• the use of the word ‘he’ in Article 11 meant the consequences of failing a weigh-in did not apply to a female wrestler.

Phogat made the following requests for relief:

• the decision to disqualify her and all of its effects should be set aside; and
• she remain eligible and qualified to be awarded the silver medal.

Decision

In rejecting Phogat’s application, the sole arbitrator noted that:

• Phogat did not dispute the fact she was over the weight limit and that there is no discretion allowed in the Rules, notwithstanding Phogat’s submissions;
• despite Phogat’s argument that ineligibility should be restricted to events subsequent to the failed weigh-in, the Rules did not provide for this; and
• the Rules reflect a United World Wrestling policy that a wrestler must not only be eligible at the beginning of a competition but must also remain eligible for the whole of the competition, with the effect that there are no accumulated rights arising from partial eligibility.

Outcome

Application unsuccessful – the Panel dismissed Phogat’s application and she was not awarded a silver medal.

Espionage

The Canada football case at Paris 2024 attracted worldwide attention. The matter involved allegations of spying through the use of drones by persons associated with the Canadian women’s football team. 

Canadian Olympic Committee & Canada Soccer v. Fédération Internationale de Football Association & New Zealand Football & New Zealand Olympic Committee Inc. & Fédération Française de Football & Comité National Olympique et Sportif Franç^[21] 

Facts   

On 24 July 2024, a representative of New Zealand Football wrote to Fédération Internationale de Football Association (FIFA) reporting an incident whereby persons associated with the Canadian women’s football team had used drones to record the New Zealand team's training session of 22 July 2024 in the lead up to their first match at Paris 2024. 

The person filming the training session with the drone was a staff member of the Canadian women's football team, Joseph Lombardi (Lombardi). Lombardi was part of the Canadian delegation and his relationship with Canada Soccer was not disputed. 

On 27 July 2024 Canada Soccer sent additional information to FIFA, including an email from March 2024 exhibiting an analyst resisting a request from Beverly Priestman (Priestman), the Canadian women’s football team’s Head Coach, to engage in flying drones for scouting purposes. In this email, Priestman sought advice from another employee regarding this behaviour, stating, ‘It's something the analyst has always done, and I know there is a whole operation on the men's side with regards to it.’ 

On 27 July 2024, FIFA sanctioned Canada Soccer, Priestman, Jasmine Mander (an assistant coach to whom the analytical report was sent) and Lombardi. Canada Soccer was sanctioned as follows:  

• Canada Soccer to pay a fine to the amount of CHF 200,000; and 
• six points deducted from the Canadian women’s football team's standing in Group A of Paris 2024. 

Canada Soccer sought to challenge the six-point deduction only. 

In their submissions, Canada Soccer accepted the violations and did not seek to deny the gravity of the infringements and their full responsibility. However, it was submitted the six-point deduction was ‘grossly disproportionate’ to the contravention, and it unfairly disadvantaged the players who were unaware of the misconduct.  

Canada Soccer made the following additional arguments:  

• a point deduction was not a commonly used sanction and has only been used in ‘last resort’ scenarios;  
• the sanction is so severe as to have the potential to end the chances of the Canadian team to progress in the competition;  
• if FIFA wished to sanction the organisation and not the players, they should have issued a larger monetary fine; and 
• FIFA failed to consider mitigating factors, such as the voluntary suspension of Priestman from the New Zealand game, and the voluntarily disclosure of a piece of evidence adverse to it. 

Decision  

In making its judgment, the Panel relied significantly on CAS 2014/A/3562 which stated arbitrariness is not found where there is a mere disagreement with a specific sanction, ‘but only if the sanction concerned is to be considered as evidently and grossly disproportionate to the offence.’  

The Panel determined the points deduction sanction on Canada Soccer was not ‘grossly disproportionate’ to the violation of the rules that had occurred. The Panel did not consider the sanction outweighed the severity of the misconduct engaged in and instead acted as a positive deterrent of future misconduct.  

Further, the Panel noted that despite Canada Soccer’s assertion that a points deduction is a ‘last resort’ penalty, FIFA could have imposed a greater sanction, such as expulsion from the competition or a forfeiting of games already played. In these instances, Canada would have been precluded from participating in Paris 2024 in its entirety, whereas the points deduction penalty meant the players were still able to participate in Paris 2024 and could still qualify for the next round.  

Outcome 

Application dismissed – the Panel held that the sanction imposed by FIFA was not grossly disproportionate to the violations that occurred.

CAS Anti-Doping Division 

CAS also operates the CAS Anti-Doping Division (CAS Anti-Doping Division) as the first-instance decision-making authority for any potential doping-related disputes that arise where the application of anti-doping policies, rules and regulations impact participation in Paris 2024. These doping-related matters are referred to it by the International Testing Agency, in accordance with the IOC Anti-Doping Rules applicable to Paris 2024. 

The review of decisions of the CAS Anti-Doping Division is outside the scope of this article; however, we note the CAS Anti-Doping Division heard two cases in relation to Paris 2024.^[22] 

This article was written with the assistance of Nick Fogarty, Baxter Tilly and Sarah Vidler, Law Graduates.  

[1] Under Article 14 of the CAS Ad Hoc Division Arbitration Rules, in instances where urgent relief is sought the President of the Ad Hoc Division can make a decision. See, for example, in Krystsina Tsimanouskaya v. National Olympic Committee of Belarus.

[2] CAS Media Release 11 June 2024 ‘The Court of Arbitration for Sport (CAS) to open two temporary offices in Paris’.

[3] TAS OG 24/10 Tatiana Debien v. United World Wrestling (UWW) & International Olympic Committee (IOC); TAS OG 24/11 Adrien Coulibaly v. Comité National Olympique et Sportif Français (CNOSF). 

[4] CAS OG 24/01 Nayoka Clunis v. Jamaica Athletics Administrative Association.

[5] CAS OG 24/03 Mahmoud Al Hamid v. International Weightlifting Federation. 

[6] CAS OG 24/12 David Sánchez López v. Turkish Weightlifting Federation. 

[7] CAS OG 24/04 Iael Football Association & Mr. Roy Revivo v. Fédération Internationale de Football Association (FIFA). 

[8] CAS OG 24/14 Marta Vieira da Silva, Comitê Olímpico do Brasil (COB) & Confederação Brasileira de Futebol (CBF) v. FIFA.

[9] CAS OG 24/02 Cook Islands Aquatics Federation and Cook Islands Sports and National Olympic Committee v. World Aquatics.

[10] What are universality places and who can obtain one?   

[11] CAS OG 24/05 Livia Avancini v. World Athletics.

[12] CAS OG 24/06 Max Batista v. World Athletics.

[13] CAS OG 24/07 Hygor Bezerra v. World Athletics.

[14] CAS OG 24/08 Jitka Čábelická v. Czech Cycling Federation & Czech Olympic Committee. 

[15] CAS OG 24/13 Dany Brand v. World Athletics.

[16] CAS OG 24/18 Italian Swimming Federation v. World Aquatics. 

[17] CAS OG 24-15.

[18] CAS OG 24-16.

[19] CAS OG 24/19 Benjamin Savšek & OCSASF v. International Canoe Federation.

[20] CAS OG 24/17 Vinesh Phogat v. United World Wrestling & IOC.

[21] CAS OG 24/09 Canadian Olympic Committee & Canada Soccer v. Fédération Internationale de Football Association & New Zealand Football & New Zealand Olympic Committee Inc. & Fédération Française de Football & Comité National Olympique et Sportif Franç.

[22] CAS Anti-Doping Division media release.