CAS Case Digest · Verified against the full award text

CAS 2022/A/9299 — Galatasaray Sportif A.S. v Domenec Torrent Font

"Galatasaray v Torrent Font" · CAS upheld the coach's compensation claim but ordered payment by contractual instalments rather than as a lump sum.

What happened in Galatasaray v Torrent Font

Galatasaray Sportif A.S. hired Spanish coach Domenec Torrent Font on 14 January 2022 on a contract running to 31 May 2023, with an option to extend to 31 May 2024. The contract provided for net salaries of EUR 1,275,000 for the remainder of the 2021/2022 season and EUR 1,500,000 for the 2022/2023 season, plus a monthly housing allowance of up to EUR 6,000. The club failed to pay salary and housing allowance for April and May 2022, and on 21 June 2022 terminated the contract alleging just cause based on unauthorised absence, failure to submit reports, poor team performance, and breach of trust. The coach filed a claim before the FIFA Players Status Chamber (PSC), which on 29 September 2022 found no just cause and awarded EUR 528,000 in outstanding remuneration and EUR 1,500,000 in compensation, payable as a lump sum. Galatasaray appealed to CAS. The Sole Arbitrator confirmed that the club lacked just cause, upheld the compensation quantum of EUR 1,500,000, but partially upheld the appeal by ordering payment by the contractual instalment schedule rather than as a lump sum. The case matters because it affirms that a clearly drafted contractual compensation clause governs over the default FIFA RSTP formula, and that the agreed payment modality — including instalment payment — is binding even if detrimental to the coach.

Procedural history of CAS 2022/A/9299

On 25 July 2022, Domenec Torrent Font filed a claim before the Players Status Chamber of the FIFA Tribunal (PSC), alleging breach of contract and claiming EUR 261,000 outstanding salary plus housing allowance for April 2022, EUR 261,000 for May 2022, EUR 6,000 housing allowance for June 2022, and EUR 1,500,000 as compensation (residual value of the 2022/2023 season), all with 5% interest p.a. By decision dated 29 September 2022 (case FPSD-6819), the Single Judge of the PSC partially accepted the claim, awarding all four amounts with interest, the compensation payable as a lump sum from 25 July 2022. On 30 November 2022, Galatasaray filed a Statement of Appeal with CAS under Article R48 of the CAS Code, requesting that the termination be found to have been with just cause, or alternatively that the compensation clause be declared null and void or reduced, and that in any event the lump-sum payment order be replaced by instalment payments as contractually agreed.

Key holdings in CAS 2022/A/9299

• The club did not have just cause to terminate the contract on 21 June 2022, as none of the alleged breaches — unauthorised absence, failure to report, poor team performance, or the timing of the salary demand — were proved to a standard that rendered continuation of the employment relationship unreasonable.
• A contractual compensation clause (Article 4 of the Contract) has primacy over the default compensation formula in Article 6 of Annexe 2 of the FIFA RSTP, which applies only subsidiarily.
• Article 4 of the Contract is valid and not disproportionate, excessive or null and void; the absence of reciprocal obligations does not invalidate a liquidated damages clause provided the club has not entered into an excessive commitment that disproportionately favours the other party.
• The compensation of EUR 1,500,000 (residual value of the 2022/2023 season) must be paid by the contractual instalment schedule, not as a lump sum, because the parties — both legally represented — expressly agreed to that payment modality.
• The CAS de novo review under Article R57 of the Code cures any procedural defect at the PSC level, rendering the ne ultra petita argument against the PSC decision moot.

How the CAS panel reasoned

The Sole Arbitrator assessed each alleged ground for just cause individually. On unauthorised absence, the only evidence was an on-site inspection report showing the coach was absent from the training ground between 7:23 am and 10:47 am on 21 June 2022 — insufficient to establish a month-long unauthorised absence, especially with no return-to-work request or disciplinary proceedings. On failure to report under Articles 2.21 and 2.22, no request or warning had ever been issued, and the obligation's timing was undefined. On poor team performance, the club provided no objective evidence attributing results to the coach, who inherited a team already in 12th place after 20 matches; moreover, no express contractual clause permitted termination for poor results. On the salary demand, the coach was entitled to demand overdue payments, particularly after the club itself raised contract termination at the 20 June 2022 meeting. The post-match interview allegation was raised only in the appeal brief, not in the dismissal letter, and the club provided no evidence it was unaware of the interview at the time of termination. On compensation, the Sole Arbitrator applied the CAS test of whether the clause created an excessive commitment disproportionately favouring one party, found it did not, and upheld Article 4 as valid. She rejected the lump-sum payment order, finding the instalment modality was freely negotiated by legally represented parties and offset by the no-mitigation provision.

Why Galatasaray v Torrent Font matters in CAS jurisprudence

The award reinforces that a clearly drafted contractual compensation clause in a coach's employment contract takes precedence over the default formula in Article 6 of Annexe 2 of the FIFA RSTP, and that the agreed payment modality — including instalment payment — binds the adjudicating body even if it is less favourable to the coach. It also confirms that unsubstantiated allegations of poor team performance, absent an express contractual termination-for-results clause, cannot constitute just cause for dismissal.

Cases cited in this award

CAS 2020/A/7175 CAS 2020/A/6798 CAS 2017/A/5402 CAS 2016/A/4826 CAS 2019/A/6533 CAS 2018/A/5771

Frequently asked questions about Galatasaray v Torrent Font

Did Galatasaray have just cause to fire Domenec Torrent Font?

No. The Sole Arbitrator found that none of the club's allegations — unauthorised absence, failure to submit reports, poor team performance, or the timing of the coach's salary demand — were proved to the standard required for just cause. The club's only evidence of absence was an inspection report covering less than four hours on a single day, no return-to-work request had been made, and poor team performance without an express contractual clause cannot justify immediate dismissal.

How much compensation did Galatasaray have to pay Torrent Font?

Galatasaray was ordered to pay EUR 528,000 in outstanding remuneration (EUR 261,000 for April 2022, EUR 261,000 for May 2022, and EUR 6,000 housing allowance for June 2022) plus EUR 1,500,000 as compensation for breach of contract, all with 5% per annum interest. The compensation of EUR 1,500,000 represented the residual value of the 2022/2023 season salary.

Was the EUR 1,500,000 compensation paid as a lump sum or in instalments in the Galatasaray v Torrent Font case?

CAS partially upheld Galatasaray's appeal on this specific point. The PSC had ordered a lump-sum payment, but the Sole Arbitrator held that Article 4 of the contract expressly required payment by the instalment schedule set out in Article 1 — ten monthly payments of EUR 150,000 each — and that this freely negotiated modality was binding. Interest at 5% p.a. runs from the day after each instalment's due date.

Can a club rely on a post-match interview as just cause for terminating a coach's contract if it was not mentioned in the dismissal letter?

Not in the circumstances of this case. The Sole Arbitrator held that CAS jurisprudence allows a party to rely on facts existing before termination but unknown at the time only in exceptional circumstances. Because the interview took place on 1 May 2022 — more than a month before the 21 June 2022 dismissal — and the club provided no evidence that it was unaware of the interview at the time of termination, the allegation was disregarded entirely.

Topics: Art. 17 RSTP & contract termination at CAS

Source: official award. This digest was generated by LexXi from the full award text and machine-verified against it — every figure, article and citation above appears in the source. It is an editorial summary, not legal advice. See how ElevenLex verification works.