CAS Case Digest · Verified against the full award text

CAS 2025/A/11493 — Daniel Pîrvu v. Romanian Football Federation

"Pîrvu" · CAS reduced a Romanian coach's two-year ban to six months for falsely identifying a sent-off player in a match report to protect his son.

What happened in Pîrvu

Daniel Pîrvu, a Romanian football coach at LPS Viitorul Pitești, coached a U13 match on 11 August 2024. When his son David Pîrvu was sent off wearing shirt number 10, the coach deliberately wrote another player's name — Tiberiu Sandu — into the official match report, causing Sandu to receive a three-match ban and RON 500 penalty he did not deserve. After Sandu's father complained, an investigation revealed the deception. The RFF Disciplinary and Ethics Committee imposed a two-year ban under Article 59(1)/(2) of the RFF Disciplinary Regulations, upheld by the RFF Appeals Committee. Pîrvu appealed to CAS. The Sole Arbitrator confirmed the Match was an official fixture between LPS Viitorul Pitești and CSM Slatina (not a friendly against Athletic Slatina as the coach claimed), upheld the finding of a violation of Article 59 RFF DC, but reduced the sanction from two years to six months commencing 20 February 2025. The case matters because it applies the proportionality principle to a fixed-sanction disciplinary rule in Romanian football, confirms CAS's de novo power overrides national evidentiary restrictions on match reports, and clarifies that a 'written lie' in an official document can constitute issuing an incorrect document under Article 59 RFF DC.

Procedural history of CAS 2025/A/11493

On 11 August 2024 a U13 official match was played. Following a complaint by the father of wrongly-sanctioned player Tiberiu Sandu, the RFF Disciplinary and Ethics Committee (RFF DEC) held a hearing on 2 December 2024. On 13 January 2025 (grounds communicated 20 February 2025) the RFF DEC issued Decision No. 854.1/CDE/2024 imposing a two-year ban from all football-related activities on Pîrvu under Article 59(1)/(2) RFF DC. Pîrvu appealed to the RFF Appeals Committee (RFF AC) on 22 February 2025; a hearing was held on 17 April 2025. On 8 May 2025 the RFF AC issued Decision No. 7/CR/2025 (notified 25/26 May 2025) dismissing the appeal and confirming the two-year ban. Pîrvu filed his CAS Statement of Appeal on 16 June 2025 and his Appeal Brief on 22 June 2025. The RFF filed its Answer on 21 July 2025. A hearing was held by videoconference on 2 March 2026. CAS was asked to set aside the Appealed Decision, declare the proceedings inadmissible, or alternatively reduce the sanction.

Key holdings in CAS 2025/A/11493

• The CAS de novo review cures any violation of the right to be heard committed during national disciplinary proceedings, rendering it unnecessary to adjudicate those procedural defects separately.
• Article 103 RFF DC's restriction of rebuttal of match report contents to video or photographic evidence does not bind CAS, which exercises full de novo review of facts and law under Article R57(1) CAS Code.
• The Match of 11 August 2024 was an official fixture between LPS Viitorul Pitești and CSM Slatina, established to the Sole Arbitrator's comfortable satisfaction notwithstanding the match report's erroneous reference to Athletic Slatina.
• A coach who hand-drafts and signs a part of an official match report containing a false player identification 'issues an incorrect document' within the meaning of Article 59(1) RFF DC, even if the overall report is signed by the referee.
• The two-year fixed sanction under Article 59(2) RFF DC is evidently and grossly disproportionate on the facts of this case, and Article 14a RFF DC provides a sufficient legal basis to reduce it; the proportionate sanction is a six-month ban commencing 20 February 2025.

How the CAS panel reasoned

The Sole Arbitrator first confirmed CAS jurisdiction and the admissibility of the appeal. On the identity of the opposing team, he weighed the match report (which named Athletic Slatina but was filled in by the opposing coach, not the referee), witness testimony from the main referee confirming the match was against CSM Slatina, the formal registration of all opposing players for CSM Slatina on the RFF platform on 9 August 2024, the implausibility of an entire unscheduled team travelling to another city, and the absence of any discussion about the match's official character on the day. He concluded to his comfortable satisfaction that the match was official. On Article 59 RFF DC, applying a restrictive interpretive approach required by CAS jurisprudence (CAS 2011/A/2612), he held that the provision covers not only classic forgery but also a 'written lie' in an official document, and that the coach was the exclusive author of the false entry. On proportionality, he found the offense less severe than classic forgery, noted the referee's own negligence enabled the violation, observed that no competition results were tracked in the youth league, and — in dubio pro reo — credited the Appellant's allegation that he was summoned to the disciplinary hearing without notice of its subject matter, depriving him of legal preparation. Balancing these factors against the intentional nature of the act and the coach's role-model responsibilities, he reduced the ban to six months under Articles 59 and 14a RFF DC.

Why Pîrvu matters in CAS jurisprudence

Pîrvu establishes that CAS's de novo review power under Article R57(1) CAS Code overrides national evidentiary rules restricting rebuttal of match reports to video/photographic evidence. It also confirms, citing CAS 2024/A/10269, that Article 123(3) RFF DC incorporates CAS proportionality jurisprudence into Romanian football disciplinary decisions, and that Article 14a RFF DC can justify deviation from a fixed sanction — not merely from a range — where the danger caused is minimal, extending the proportionality principle to single-figure fixed penalties in RFF proceedings.

Cases cited in this award

CAS 2009/A/1545 CAS 94/129 CAS 2013/A/3155 CAS 2024/A/1093 CAS 2010/A/2172 CAS 2024/A/10269

Frequently asked questions about Pîrvu

What did the Pîrvu CAS case decide about the two-year ban for falsifying a match report in Romanian football?

CAS confirmed that coach Daniel Pîrvu violated Article 59(1) RFF DC by writing a false player name into the official match report to protect his son from a sending-off sanction. However, the Sole Arbitrator found the two-year fixed ban evidently and grossly disproportionate given the minimal danger to competition integrity and the referee's own contributory negligence, and reduced it to six months commencing 20 February 2025 under Articles 59 and 14a RFF DC.

Can CAS ignore the RFF rule that match report errors can only be rebutted by video or photographic evidence?

Yes. In Pîrvu, the Sole Arbitrator held that Article 103(2) RFF DC's restriction to video or photographic rebuttal does not bind CAS because Article R57(1) CAS Code grants the panel full power to review facts and law de novo. Applying that restriction would risk forcing CAS to base a decision on facts it could determine were incorrect, which would contravene the aim of reaching a justified and equitable conclusion.

Does a 'written lie' in a match report count as issuing a false document under Article 59 RFF DC?

According to the Pîrvu award, yes. The Sole Arbitrator held that Article 59(1) RFF DC covers not only classic forgery (creating a document that misrepresents its originator) but also the issuance of an 'incorrect document,' which includes a written false statement. Because Pîrvu hand-drafted and signed the relevant entry himself, he was the exclusive author of that part of the official document and therefore 'issued' an incorrect document within the meaning of the provision.

Can the proportionality principle reduce a fixed two-year sanction under Article 59 RFF DC in Romanian football?

Yes, as confirmed in Pîrvu. The Sole Arbitrator held that Article 14a RFF DC, combined with the overarching CAS proportionality principle incorporated via Article 123(3) RFF DC, provides a sufficient legal basis to deviate from a fixed sanction where the danger is minimal. He noted that RFF bodies had already applied Article 14a to exceed sanction ranges in other cases, and that deviating from a single fixed sanction is not fundamentally different. The sanction was reduced from two years to six months.

Topics: Doping, ethics & governance at CAS

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