CAS Case Digest · Verified against the full award text

CAS 2025/A/11664 — Kyriakos Stratouras v. World Taekwondo

"Stratouras" · CAS declined jurisdiction because the appellant failed to exhaust an available internal appeal to the WT Appeal Panel before approaching CAS.

What happened in Stratouras

Kyriakos Stratouras, a taekwondo coach in Cyprus, filed a disciplinary complaint with World Taekwondo (WT) on 9 April 2025 alleging multiple governance and competition-access violations by the Cyprus Taekwondo Federation (EOTK). On 22 July 2025, WT dismissed the complaint under Articles 3.3(E) and 5.4(B)(i) of its Disciplinary Actions and Appeals Code (DAAC), citing lack of jurisdiction and the primacy of domestic authorities, and erroneously declared the decision 'final and not subject to appeal.' Stratouras appealed directly to CAS on 6 August 2025. He also filed three separate requests for provisional measures seeking access to the TPSS registration system so his athletes could compete in various 2026 Cyprus championships; all three were rejected. The Sole Arbitrator found that, although WT's dismissal letter wrongly stated the decision was unappealable, Article 5.4(E)(i) DAAC unambiguously granted any party the right to appeal an administrative closure to the WT Appeal Panel. A cursory reading of the DAAC would have revealed this right. Because Stratouras bypassed that internal remedy and no WT Appeal Panel decision existed for CAS to review, CAS lacked jurisdiction under Article R47 of the CAS Code and Article 4.12 DAAC. The case matters because it reaffirms that a federation's erroneous 'no appeal' statement does not automatically confer CAS jurisdiction when the applicable rules plainly provide an internal remedy.

Procedural history of CAS 2025/A/11664

On 9 April 2025, Stratouras filed a disciplinary complaint with WT under Article 3.3 DAAC alleging governance and competition-access violations by EOTK. WT processed the complaint, sought clarifications, and contacted EOTK and KOA. On 22 July 2025, WT issued Decision DM25-027 (CYP) dismissing the complaint under Articles 3.3(E) and 5.4(B)(i) DAAC on jurisdictional grounds, declaring the decision 'final and not subject to appeal.' On 6 August 2025, Stratouras filed a Statement of Appeal with CAS under Article R47 of the CAS Code. On 16 August 2025, he filed his Appeal Brief. The Respondent declined to pay its share of the advance of costs, asserting CAS lacked jurisdiction. The Appellant paid the full advance of costs. The Sole Arbitrator was appointed on 4 February 2026. Three requests for provisional measures were filed and rejected. The Order of Procedure was issued on 10 April 2026. The Sole Arbitrator decided the matter on the basis of written submissions without a hearing pursuant to Article R57 of the CAS Code.

Key holdings in CAS 2025/A/11664

• CAS lacks jurisdiction under Article R47 of the CAS Code and Article 4.12 DAAC where the appellant has not first obtained a final decision from the WT Appeal Panel.
• Article 5.4(E)(i) DAAC unambiguously grants any party the right to appeal an administrative closure decision to the WT Appeal Panel, regardless of a contrary statement in the decision itself.
• A federation's erroneous declaration that a decision is 'unappealable' does not dispense with the exhaustion-of-internal-remedies requirement where the applicable rules plainly provide an internal appeal avenue.
• The Sole Arbitrator's lack of jurisdiction equally requires dismissal of all requests for provisional measures filed under Article R37 of the CAS Code.
• Article 10.1.4.3 of the WT Statutes, which directs appeals exclusively to CAS after exhausting internal remedies, merely reflects the second limb of Article R47 of the CAS Code and does not independently confer CAS jurisdiction.

How the CAS panel reasoned

The Sole Arbitrator began from the Kompetenz-Kompetenz principle under Article 186 PILA, confirming CAS's authority to rule on its own jurisdiction. He then applied Article R47 of the CAS Code, which requires both a regulatory basis for CAS appeal and exhaustion of internal remedies. Article 4.12(A) DAAC limits CAS jurisdiction to final decisions of the WT Appeal Panel, and Article 4.12(B) DAAC states that submission to CAS occurs only where explicitly permitted. The Appealed Decision was not a WT Appeal Panel decision. The Sole Arbitrator rejected the Respondent's late attempt to recharacterise the decision as purely an Article 3.3(E) DAAC screening determination, noting that the decision expressly cited Article 5.4(B)(i) DAAC as a co-basis on multiple occasions. Article 5.4(E)(i) DAAC clearly provides a right of internal appeal for administrative closures. The Sole Arbitrator acknowledged that in cases of genuine ambiguity, a federation's erroneous 'no appeal' statement might exceptionally justify bypassing internal remedies, but held this was not such a case: a cursory reading of the DAAC would have revealed the internal appeal right. The Appellant's failure to attempt that internal appeal was a fundamental flaw CAS could not correct. The Sole Arbitrator also noted the Respondent's own acknowledgment that the GIU's erroneous statement and the unique procedural circumstances might constitute 'extraordinary circumstances' justifying a late internal appeal, and strongly encouraged WT to explore that avenue.

Why Stratouras matters in CAS jurisprudence

This award reinforces that a sports federation's erroneous 'no appeal' statement in a decision does not automatically vest CAS with jurisdiction when the federation's own rules plainly provide an internal appeal mechanism. It clarifies that Article 4.12 DAAC limits CAS jurisdiction strictly to final WT Appeal Panel decisions, and that Article 5.4(E)(i) DAAC creates an unambiguous internal appeal right for administrative closures. The award also signals, through the Sole Arbitrator's strong encouragement to WT, that federations bear responsibility for the procedural consequences of their own erroneous statements.

Cases cited in this award

CAS 2011/A/2421 & 2450 General Taweep Jantararoj v. AIBA CAS 2011/A/2576 Curaçao Sport and Olympic Federation v. International Olympic Committee (IOC) CAS 2021/A/8031 USF et al. v. FINA CAS 2020/A/6747 Mehdi Sohrabi v. Union Cycliste Internationale CAS 2018/A/5853 FIFA v. TNDA & Damián Marcelo Musto CAS 2008/A/1571 Nusaybindemir SC v. TFF & Sirnak SC

Frequently asked questions about Stratouras

Why did CAS dismiss the Stratouras v. World Taekwondo appeal for lack of jurisdiction?

CAS lacked jurisdiction because Stratouras appealed directly to CAS without first exhausting the internal appeal available to him under Article 5.4(E)(i) DAAC, which expressly allows any party to appeal an administrative closure to the WT Appeal Panel. Under Article 4.12 DAAC, CAS jurisdiction is limited to final decisions of the WT Appeal Panel, and no such decision existed in this case.

Does a federation's erroneous 'no appeal' statement in a decision allow a party to skip internal remedies and go straight to CAS?

Not automatically, according to the Stratouras award. The Sole Arbitrator acknowledged that in cases of genuine ambiguity, such an error might exceptionally justify bypassing internal remedies. However, because Article 5.4(E)(i) DAAC unambiguously provided an internal appeal right and the Appealed Decision itself cited Article 5.4(B)(i) DAAC, a cursory reading of the rules would have revealed the available remedy, so the erroneous statement did not excuse the failure to exhaust it.

What happened to Stratouras's requests for provisional measures seeking TPSS access for his athletes?

All three requests for provisional measures filed under Article R37 of the CAS Code were rejected. The Sole Arbitrator held that the lack of CAS jurisdiction over the main appeal was equally the basis for dismissing the First, Second, and Third Requests for Provisional Measures, which had sought either restoration of TPSS access or authorisation for athletes to participate in the Cyprus Junior Championships 2026, the Cyprus National Cadet Championships 2026, and the Cyprus National Senior Championships 2026.

What did the Sole Arbitrator say about the possibility of Stratouras still pursuing an internal appeal within World Taekwondo?

The Sole Arbitrator noted that the Respondent itself acknowledged in its 24 February 2026 response that the GIU's erroneous 'no appeal' statement and the unique procedural circumstances of the case might constitute 'extraordinary circumstances' justifying a late internal appeal under Article 4.4(B) DAAC. On that basis, the Sole Arbitrator strongly encouraged WT to explore avenues to permit Stratouras to pursue an internal appeal within the WT framework.

Topics: Doping, ethics & governance 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.