CAS Case Digest · Verified against the full award text
CAS 2024/A/10956 — Anyuta Galstyan v. Okzhetpes Futbol Kluby
"Galstyan" · CAS awarded an Armenian footballer KZT 2,900,000 compensation for injury-related losses after her Kazakhstani club's contract expired.
| Award date | 28 August 2025 |
| Panel | Sole Arbitrator: Mr Espen Auberg, Attorney-at-Law, Oslo, Norway |
| Outcome | Appeal partially upheld; Okzhetpes must pay Galstyan KZT 31,808 plus 5% p.a. interest from 12 October 2023, KZT 54,805 plus 5% p.a. interest from 12 October 2023, and KZT 2,900,000 as compensation; all other claims dismissed. |
| Provisions | Art. 17(1) FIFA RSTP Art. 14(2) FIFA RSTP Art. 13 FIFA RSTP Art. 22(1-b) FIFA RSTP Art. 24 FIFA RSTP Art. 49(2) FIFA Statutes (2024 edition) Art. 50(1) FIFA Statutes (May 2024 edition) Art. R47 CAS Code Art. R48 CAS Code Art. R49 CAS Code Art. R51 CAS Code Art. R54 CAS Code Art. R55 CAS Code Art. R56 CAS Code Art. R58 CAS Code Art. 18(1) Swiss Code of Obligations Art. 8 Swiss Civil Code Art. 49 paragraph 2 Kazakhstan Labor Code Art. 52 paragraph 20 Kazakhstan Labor Code Art. 133 paragraph 2 Kazakhstan Labor Code Art. 133 paragraph 5 Kazakhstan Labor Code Art. 2 paragraph 1 Procedural Rules Governing the Football Tribunal (March 2023) Art. 23 paragraph 1 Procedural Rules Governing the Football Tribunal (March 2023) Art. 34 Procedural Rules Governing the Football Tribunal (March 2023) |
What happened in Galstyan
Anyuta Galstyan, an Armenian professional footballer, signed a six-month contract with Kazakhstani club Okzhetpes Futbol Kluby from 11 April to 11 October 2023 at KZT 290,000 per month. On 6 October 2023, five days before the contract's natural expiry, she suffered a left knee injury during a match, later diagnosed as a medial meniscus rupture and partial ACL damage. The contract expired on 11 October 2023. The Player underwent surgery in Yerevan on 11 December 2023 and was advised to rejoin professional football 8–9 months post-surgery. She filed a claim before the FIFA DRC, which awarded her only KZT 86,613 in outstanding remuneration and crutch reimbursement, rejecting her claims for damages, social allowance, and moral damages. She appealed to CAS. The Sole Arbitrator upheld the contract's valid expiry but found that the Club's contractual obligations under Articles 2.1.2, 2.1.8, and 2.1.10 — covering occupational safety, health compensation, and accident insurance — were not extinguished by expiry, as the Club drafted the contract and the parties never intended to limit post-expiry compensation. The arbitrator calculated damages at KZT 290,000 × 10 months (11 October 2023 to 11 August 2024), awarding KZT 2,900,000. The case matters because it confirms that contractual injury-compensation obligations can survive a fixed-term contract's natural expiry.
Procedural history of CAS 2024/A/10956
On 16 January 2024, Galstyan filed a claim before the FIFA Dispute Resolution Chamber (FIFA DRC) seeking KZT 7,838,694.33 in total, including wages, damages, social allowance, and moral damages. On 8 August 2024, the FIFA DRC rendered its decision (communicated 2 October 2024), partially accepting the claim and awarding only KZT 31,808 as outstanding remuneration and KZT 54,805 as reimbursement for crutches, both with 5% interest p.a. from 12 October 2023, while rejecting all other claims. On 23 October 2024, the Player filed a Statement of Appeal with CAS against the Club and FIFA. On 18 February 2025, she withdrew the appeal against FIFA. The Club filed its Answer on 11 March 2025. The Sole Arbitrator decided the case on written submissions without a hearing, issuing the award on 28 August 2025.
Key holdings in CAS 2024/A/10956
- The fixed-term contract validly expired on 11 October 2023 by effluxion of time, and the document signed by the Player on that date merely confirmed the expiry rather than constituting a separate termination.
- Article 52 paragraph 20 of the Kazakhstan Labor Code, which governs employer-initiated terminations, is inapplicable where a contract ends by expiration of its term.
- Contractual obligations under Articles 2.1.2, 2.1.8, and 2.1.10 of the Contract — covering occupational safety, health compensation, and accident insurance — are not automatically extinguished upon the contract's expiry, particularly where the contract was drafted by the Club and the parties never discussed limiting post-expiry compensation.
- Applying Article 18 paragraph 1 of the Swiss Code of Obligations, ambiguous contract terms must be interpreted against the drafting party (in dubio contra stipulatorem), here the Club.
- The Player's recoverable compensation period runs from 11 October 2023 to 11 August 2024 (10 months at KZT 290,000), as the medical evidence supported recovery 8–9 months after the 11 December 2023 surgery, not the 14 September 2024 date claimed.
How the CAS panel reasoned
The Sole Arbitrator first confirmed the contract expired naturally on 11 October 2023, rejecting the Player's argument that the Club was obliged to extend it under Article 52 paragraph 20 of the Kazakhstan Labor Code, which applies only to employer-initiated terminations. He then examined whether injury-compensation rights under Articles 2.1.2, 2.1.8, and 2.1.10 survived expiry. Applying Article 18 paragraph 1 of the Swiss Code of Obligations, he sought the parties' true common intention, noting the contract was drafted by the Club and the parties never discussed limiting the scope of compensation. Under the principle in dubio contra stipulatorem, he resolved the ambiguity against the Club, holding that compensation obligations were not time-limited to the contract period. He rejected the Club's argument that the Player should have remained in Kazakhstan for treatment, noting the Club never established it had actually contracted any social insurance. He adjusted the recovery period from the Player's claimed 14 September 2024 to 11 August 2024, based on the medical recommendation of 8–9 months post-surgery from 11 December 2023. Moral damages were dismissed as unsubstantiated and lacking legal basis. Social allowance claims were rejected to avoid double recovery.
Why Galstyan matters in CAS jurisprudence
This award establishes that a professional footballer's contractual rights to injury compensation — including occupational safety, health damage compensation, and accident insurance — can survive the natural expiry of a fixed-term contract where the contract was drafted by the club and the parties never agreed to limit post-expiry liability. It also applies the in dubio contra stipulatorem principle to resolve ambiguous compensation clauses against the drafting club, and clarifies that the recovery period for damages must be grounded in medical evidence rather than the player's own assertions.
Decision: Appeal partially upheld; Okzhetpes must pay Galstyan KZT 31,808 plus 5% p.a. interest from 12 October 2023, KZT 54,805 plus 5% p.a. interest from 12 October 2023, and KZT 2,900,000 as compensation; all other claims dismissed.
Cases cited in this award
CAS 2015/A/4220 CAS 2020/A/6796 CAS 2005/A/871 CAS 2021/A/7909 CAS 2008/A/1518
Frequently asked questions about Galstyan
Did Galstyan win her CAS appeal against Okzhetpes after her knee injury?
Yes, partially. CAS upheld her appeal in part, awarding her KZT 2,900,000 as compensation for injury-related losses on top of the KZT 86,613 already awarded by the FIFA DRC. Her claims for moral damages, social allowance, and wages beyond 11 October 2023 were dismissed.
Can a club's injury compensation obligations survive the expiry of a fixed-term contract under CAS jurisprudence?
According to this award, yes. The Sole Arbitrator held that Articles 2.1.2, 2.1.8, and 2.1.10 of the contract — covering occupational safety, health compensation, and accident insurance — were not extinguished by the contract's natural expiry on 11 October 2023. Applying Article 18(1) of the Swiss Code of Obligations and the principle in dubio contra stipulatorem, ambiguous terms were construed against the Club as drafter.
How did CAS calculate the KZT 2,900,000 compensation awarded to Galstyan?
The Sole Arbitrator multiplied the Player's monthly salary of KZT 290,000 by 10 months, covering the period from 11 October 2023 to 11 August 2024. He rejected the Player's claimed recovery date of 14 September 2024, instead using 11 August 2024 based on the medical recommendation that she rejoin professional football 8–9 months after her surgery on 11 December 2023.
Was the termination of Galstyan's contract on 11 October 2023 declared null and void by CAS?
No. The Sole Arbitrator held that the contract validly expired on 11 October 2023 by effluxion of time under Article 7.1.2 of the contract and Article 49 paragraph 2 of the Kazakhstan Labor Code. The document signed by the Player on that date merely confirmed the expiry. The Player's claim that she terminated the contract with just cause on 14 October 2023 was therefore not considered.
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