CAS Case Digest · Verified against the full award text

CAS 2025/A/11891 — Napredak Football Club v. Damir Sadiković & FK Sloga Doboj

"Napredak v. Sadiković" · CAS ratified a consent award settling Napredak's appeal of a FIFA DRC compensation order for EUR 15,000.

What happened in Napredak v. Sadiković

Napredak Football Club (Serbia) and player Damir Sadiković signed an employment contract on 15 September 2023 running until 31 May 2025. After the club excluded the player from first-team training from late June 2024 and left several salary instalments and a EUR 11,000 signing fee unpaid, the player terminated the contract with just cause on 7 August 2024 and joined FK Sloga Doboj two days later. The player filed a claim before the FIFA Dispute Resolution Chamber (DRC), which on 3 July 2025 ordered Napredak to pay EUR 39,304.28 as compensation for breach of contract plus 5% interest p.a. from 7 August 2024. Napredak appealed to CAS on 29 October 2025, seeking annulment of the DRC decision and, alternatively, a finding that the player had terminated without just cause, with compensation of EUR 99,845.16 flowing back to the club. At the hearing on 17 March 2026, the parties negotiated a settlement: Napredak agreed to pay the player EUR 15,000 in two instalments (EUR 10,000 by 31 March 2026; EUR 5,000 by 15 May 2026), with CAS procedural costs borne by Napredak and each party bearing its own legal fees. The Sole Arbitrator ratified the settlement as bona fide and not contrary to public policy, issuing a consent award on 6 May 2026. The case illustrates how employment-contract disputes involving training exclusion and unpaid wages are resolved through negotiated consent awards at CAS.

Procedural history of CAS 2025/A/11891

On 26 August 2024, the player filed a claim before the FIFA DRC (ref. FPSD-15911) seeking overdue wages, the EUR 11,000 signing fee, and EUR 46,000 in compensation. The club filed a counter-claim on 16 October 2024. On 3 July 2025, the DRC partially accepted the player's claim, ordering Napredak to pay EUR 39,304.28 as compensation for breach of contract plus 5% interest p.a. from 7 August 2024, and rejected the counter-claim. The parties were notified of the decision on 9 October 2025. Napredak lodged its Statement of Appeal with CAS on 29 October 2025 under Article R47 of the CAS Code, initially naming FIFA as a respondent but later withdrawing that designation. The President of the CAS Appeals Arbitration Division appointed Mr Patrick Grandjean as Sole Arbitrator on 30 December 2025. A hearing was held on 17 March 2026, during which the parties reached a settlement that was formalised on 23 March 2026 and filed with CAS on 25 March 2026.

Key holdings in CAS 2025/A/11891

• CAS has jurisdiction to issue a consent award where the parties expressly agree to resolve the arbitration by means of an award incorporating their settlement agreement, pursuant to Article R47 of the CAS Code and Article 50 of the FIFA Statutes.
• Under Swiss law, an arbitral tribunal sitting in Switzerland may issue an award embodying the terms of a parties' settlement, vesting it with res judicata effect and enabling enforcement.
• The Sole Arbitrator must verify that a settlement agreement is bona fide, that the parties' will has not been manipulated to commit fraud, and that the terms are not contrary to public policy or mandatory rules of applicable law before ratifying it.
• FK Sloga Doboj, having failed to respond within the prescribed deadline after the CAS Court Office's letter of 26 March 2026, was deemed to have validly approved the terms of the Settlement Agreement.
• A consent award terminates the CAS arbitration proceedings and the settlement amount of EUR 15,000 constitutes full and final satisfaction of all claims arising from the DRC decision and the dispute.

How the CAS panel reasoned

The Sole Arbitrator's reasoning was confined to the procedural and supervisory role appropriate to a consent award. He confirmed CAS jurisdiction on the basis of Article R47 of the CAS Code and Article 50 of the FIFA Statutes, reinforced by the parties' express agreement in the Settlement Agreement to resolve the proceedings by consent award. Applying Swiss law as the lex arbitri, he noted that a Swiss-seated tribunal has authority to embody a settlement in an award to give it res judicata effect and enforceability. His substantive task was limited to verifying the bona fide character of the Settlement Agreement: he reviewed the agreement's terms and the file evidence and found no grounds to object, no indication of fraud or manipulation of the parties' will, and no conflict with public policy or mandatory rules. He accepted that FK Sloga Doboj's silence following the CAS Court Office's 26 March 2026 letter constituted deemed approval. No merits analysis of the underlying just-cause termination or compensation quantum was conducted, as the settlement rendered such analysis unnecessary. Costs were allocated in accordance with the parties' agreement: CAS procedural costs borne solely by Napredak, with each party bearing its own legal fees.

Why Napredak v. Sadiković matters in CAS jurisprudence

This consent award illustrates the standard CAS supervisory framework for ratifying party settlements under Article R56 of the CAS Code and Swiss arbitration law. It confirms that a sole arbitrator's role in consent proceedings is limited to verifying bona fides and absence of public-policy violations, without re-examining the merits. The case also demonstrates how a DRC award of EUR 39,304.28 can be resolved for EUR 15,000 through negotiation at the CAS hearing stage, and how a non-participating second respondent is treated as having approved settlement terms by silence.

Frequently asked questions about Napredak v. Sadiković

What did the FIFA DRC award in the Napredak v. Sadiković case before the CAS appeal?

On 3 July 2025, the FIFA Dispute Resolution Chamber ordered Napredak Football Club to pay Damir Sadiković EUR 39,304.28 as compensation for breach of contract plus 5% interest p.a. from 7 August 2024 until the date of effective payment. The DRC partially accepted the player's claim and rejected the club's counter-claim. The parties were notified of the decision on 9 October 2025.

Why did Damir Sadiković terminate his contract with Napredak with just cause?

The player terminated the employment contract on 7 August 2024, citing the club's failure to pay part of his March 2024 salary, his June 2024 salary, his July 2024 salary, and the EUR 11,000 signing fee for the 2024/25 season. He also alleged that he had been forced to train alone for more than a month, excluded from the first team's pre-season camp in Slovenia from 27 June to 8 July 2024, and subjected to discriminatory treatment based on nationality following a public statement by the club's general secretary.

How much did Napredak ultimately pay Sadiković under the CAS consent award settlement?

Under the Settlement Agreement dated 23 March 2026 and ratified by the CAS consent award of 6 May 2026, Napredak agreed to pay Sadiković EUR 15,000 in two instalments: EUR 10,000 by 31 March 2026 and EUR 5,000 by 15 May 2026. This represented a significant reduction from the EUR 39,304.28 ordered by the FIFA DRC. Full and timely payment constituted final satisfaction of all claims arising from the DRC decision and the dispute.

What happens if Napredak fails to pay the settlement amount under the Napredak v. Sadiković consent award?

The Settlement Agreement provides that if the club fails to pay the full outstanding amount within an additional five business days after the due date, the player is entitled to enforce the agreement before FIFA disciplinary bodies. The agreement expressly states that payment obligations constitute financial obligations within the meaning of the FIFA Disciplinary Code, allowing the player to request the intervention of the FIFA Disciplinary Committee for enforcement, including the imposition of disciplinary measures.

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.