Labour Disputes
Texto da decisão
REF. FPSD-20677
Decision of the
Dispute Resolution Chamber
passed on 17 November 2025
regarding an employment-related dispute concerning the player Bruno
Ferreira dos Santos
BY:
André DOS SANTOS MEGALE, Brazil
CLAIMANT:
Bruno Ferreira dos Santos, Brazil
Represented by Filipe Orsolini Pinto de Souza
RESPONDENT:
Bouri SC, Bahrain
pg. 2
REF. FPSD-20677
I. Facts of the case
1.
On 7 September 2024, the Brazilian player Bruno Ferreira dos Santos (hereinafter: the
Player or the Claimant) and the Bahraini club Bouri SC (hereinafter: the Club or the
Respondent) concluded an employment contract (hereinafter: the Employment Contract)
valid from 5 September 2024 until 30 May 2025.
2.
Clause 4.11 of the Employment Contract established as follows (quoted verbatim):
“Article (4): Obligations of the [Club]
[…]
11 – The [Club]is obligated to cover the full treatment expenses for sports injuries and the
rehabilitation of the [Player]y, provided that the latter’s injury occurred during training,
playing or performing the services subject of the Contract without prejudice to regular
payments of their dues during the treatment and rehabilitation period. (The player’s salary
shall be determined by agreement during the period of injury. If not specified in the contract
clauses, the general text in the Players’ Status and Transfer Regulation shall be applied.)“
3.
On 21 February 2025, the Player purportedly suffered an injury on his left knee during a
match against the club Al Ittifaq for the Bahraini Premier League.
4.
On 9 March 2025, the Player underwent an MRI exam on his left knee, in accordance with
a report issued by the medical institution Al Hakeem Radiology Center, containing the
following diagnosis (quoted verbatim):
“Proximal patellar tendon full thickness tear at the medial proximal insertion. Posterior horn
medial meniscus contusion with possible tear at the capsular junction. MCL sprained.”
5.
On 25 March 2025, Dr. Ali Hasan Al Majed, from the Royal Medical Services of the Bahrain
Defense Force, issued a report on the Player’s injury under the following terms (quoted
verbatim):
“Bruno is 35 years old Brazilian male, presented to my clinic on 11th of March 2025 with knee
pain after a twisting injury while he was playing football three weeks earlier. He came walking
with normal gait, his left knee was showing no swelling, has tenderness at the patellar
attachment of the patellar tendon, has no extension lag with full range of motion of the knee
joint. MRI was showing partial tear of the proximal patellar tendon as well as MCL sprain and
ACL sprain with medial meniscus grade 2 tear. Advise to go for surgical repair, recovery time
from this surgery may take 6 to 12 months to return back to the sport activities.”
pg. 3
REF. FPSD-20677
II. Proceedings before FIFA
6.
On 3 September 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Player
7.
The Player alleged that he sustained a serious left knee injury on 21 February 2025, during
a Bahraini Premier League match against Al Ittifaq. According to him, surgical intervention
and extended physiotherapy were required, with an estimated recovery period of 6 to 12
months.
8.
The Player further contended that, under clause 4.11 of the Employment Contract, the Club
was contractually obligated to cover the full cost of treatment and rehabilitation for injuries
sustained during official duties. The Player outlined that, nonetheless, the Club failed to
provide the necessary medical care, including surgery and physiotherapy.
9.
He asserted that, following the expiration of the Employment Contract, he returned to
Brazil and engaged new medical and physiotherapy professionals to continue his
treatment. He further argued that the cost of the surgery and subsequent physiotherapy
amounted to BRL 76,100.00. In support of this, the Player submitted the following
documents:
•
A document titled “Medical Report – Surgical Budget” (hereinafter: the Surgery
Budget) issued by a medical institution named Santa Marcelina Orthopedic Clinic
on 25 July 2025, indicating that applicable surgical intervention was quoted at BRL
67,000; and
•
A document titled “Sports Physiotherapy Quote” (hereinafter: the Physiotherapy
Budget) issued by a physiotherapist called Graziele de Souza on 31 July 2025,
indicating that applicable physiotherapy treatment was quoted at BRL 9,100.
10. In light of the above, the Player requested the following relief:
“1.
In view of all above, the Claimant requests:
a.
the FIFA general secretariat to issue a proposal according to the Article 20 of the FIFA
Procedural, given that the case does not raise complex factual or legal issues;
b.
the DRC to send this claim to Buri Club (Bahrein) with a time limit for a statement or
a reply, pursuant article 21.1 the FIFA Procedural;
pg. 4
REF. FPSD-20677
c.
the DRC to accept this claim and order the Buri Club (Bahrein) to pay the Claimant the
medical expenses related to the surgery and the physiotherapy expenses in the total net
amount of BRL 76,100.00 (seventy-six thousand one hundred Brazilian reais);
d.
the DRC to accept this claim and include the consequences of the failure to pay the
relevant amount in due time, pursuant article 24 of the FIFA RSTP.”
b. Position of the Club
11. Despite being invited to do so, the Club failed to submit any response to the Player’s claim.
pg. 5
REF. FPSD-20677
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
12. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether he was competent to deal with the case at hand. In this respect, he took
note that the present matter was presented to FIFA on 3 September 2025 and submitted
for decision on 17 November 2025. Taking into account the wording of arts. 31 and 34 of
the January 2025 edition of the Procedural Rules Governing the Football Tribunal
(hereinafter: the Procedural Rules), the aforementioned edition of the Procedural Rules is
applicable to the matter at hand.
13. Furthermore, the Single Judge referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Brazilian player and a Bahraini club.
14. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, he confirmed that, in accordance with art. 29 of
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
15. The Single Judge recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which he may
consider evidence not filed by the parties, including without limitation the evidence
generated by or within the Transfer Matching System (TMS).
c. Merits of the dispute
16. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Single Judge emphasised that in the following
considerations he will refer only to the facts, arguments and documentary evidence, which
he considered pertinent for assessing the matter at hand.
pg. 6
REF. FPSD-20677
i. Main legal discussion and considerations
17. The Single Judge then moved to the substance of the matter and took note of the fact that
this is a claim from a player against a club for medical expenses.
18. The Single Judge observed that, in summary, the Player contended that the Club failed to
provide or cover the surgical care and rehabilitation treatment as contractually stipulated.
Accordingly, the Player seeks payment for medical expenses allegedly incurred in
connection with an injury sustained while performing services for the Club.
19. In parallel, the Single Judge highlighted that, since the Club did not provide its position on
the claim, the decision shall be taken solely based on the documentation on file (i.e., the
statements and documents presented by the Player) (cf., art. 21, par. 1 of the Procedural
Rules).
20. In this context, the Single Judge acknowledged that his task was to establish whether the
Player is entitled to the claimed amount, which he proceeded to analyse in turn.
21. Firstly, the Single Judge noted that although the Player did not provide direct evidence
confirming the exact circumstances of the injury allegedly sustained during a match, his
account and the nature of the injury are consistent with the findings presented in the
medical reports submitted.
22. In this regard, the Single Judge recalled that, in principle, pursuant to clause 4.11 of the
Employment Contract, the Club bears responsibility for covering the costs of the Player’s
treatment. Accordingly, the Player would, in principle, be eligible for reimbursement of
medical expenses incurred in this context, should he have borne them due to the Club’s
failure to do so.
23. Nevertheless, while acknowledging the Player’s submissions and the nature of his requests
for relief, the Single Judge observed that the Player failed to provide substantiating
documentation demonstrating that the alleged expenses were actually incurred (cf. art. 13,
par. 5 of the Procedural Rules). The only evidence presented consisted of cost estimates
and budgets, rather than proof of payment or actual expenditure (cf. Surgery Budget and
Physiotherapy Budget).
24. In light of the foregoing, the Single Judge highlighted that, based on the information
available in the case file, it remains inconclusive whether the surgery and related treatment
were performed at all. Consequently, in the absence of documentation confirming that the
surgical procedure took place and that the associated costs were effectively borne by the
Player, and considering the established jurisprudence of the Football Tribunal, the Single
Judge concluded that the Player is not entitled to reimbursement in the present matter. In
addition, the Single Judge emphasized that he is not in a position to order the Club to pay
an amount that has not yet been incurred by the Player.
pg. 7
REF. FPSD-20677
25. Consequently, the Single Judge decided to reject the Player’s claim.
d. Costs
26. The Single Judge referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Single Judge decided that no procedural costs were to be
imposed on the parties.
27. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
28. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 8
REF. FPSD-20677
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Bruno Ferreira dos Santos, is rejected.
2.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 9
REF. FPSD-20677
NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 10