Labour Disputes
Texto da decisão
REF. FPSD-21908
Decision of the
Dispute Resolution Chamber
passed on 3 February 2026
regarding an employment-related dispute concerning the player Antonio
Carlos Soares Melo
BY:
Iñigo RIESTRA, Mexico
CLAIMANT:
Antonio Carlos Soares Melo, Brazil
Represented by Lucas Silva de Oliveira
RESPONDENT:
Al Rams, United Arab Emirates
Represented by Daniel Magdi Louis
pg. 2
REF. FPSD-21908
I. Facts of the case
1.
On 20 September 2023, the Brazilian player Antonio Carlos Soares Melo (hereinafter: the
Player or the Claimant) and the Emirati club Al Rams (hereinafter: the Club or the Respondent)
concluded an employment contract (hereinafter: the Employment Contract), valid from the
date of its signature until 31 May 2024.
2.
Pursuant to clause 6 of the Employment Contract, the Club undertook to pay the Player a
monthly salary of USD 1,500, to provide one round-trip economy-class airline ticket to the
Player’s home country, and to make available a furnished single-occupancy
accommodation within the Club’s premises.
3.
On 21 April 2024, the parties concluded an agreement (hereinafter: the Termination
Agreement) to establish the conditions for the mutual termination of their employment
relationship as from 8 April 2024.
4.
Pursuant to the Termination Agreement, within the “Declaration” section, the Player
declared that he “received all [his] financial duties until 2024/04/08” and “thus, the club is
totally acquitted from any financial obligations related to [him] in accordance to the contract
that was signed between [the Parties] on the date 2023/09/20” (sic).
5.
Pursuant to the Termination Agreement, within the “Terminate the agreement for
professional soccer player” section, the parties agreed as follows (sic):
“- To end the contract between the parties and signed on 20/09/2023 which expires on
31/05/2023 consensual.
- The [Player] also acknowledges that he has received all financial dues to the contract in
question is not entitled to claim the [Club] in any financial or other benefits.
- This contract starts from 2024/04/08.
- The [Player] that [Club] has in turn care player medical care to the fullest as the contract
recognizes the player that he did not complain of any injury current or older and thus club
Rams completely innocent in this matter is not entitled to the player back to the club claim
any old injury or new injury in the near or distant future and that immediately after the
signing of this agreement.”
6.
Pursuant to the Termination Agreement, within the “Confirmation of payments by Al Rams
Sports and Cultural Club in due time” section, the Player confirmed “that AL RAMS SPORTS AND
CULTURAL CLUB has paid all its obligations arising from contractual agreements as at 30 June
2024 by the date of this letter”.
pg. 3
REF. FPSD-21908
II. Proceedings before FIFA
7.
On 13 November 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Player
8.
The Player argued that he suffered an ACL injury to his left knee during a match on 1
January 2024, and while the Club covered his medical treatment and surgery on 26 January
2024, he was later dismissed without cause on 8 April 2024. He stated that he refused to
sign the release document proposed by the Club because “the Club did not pay him
anything”.
9.
He further claimed that due to the seriousness of the injury, he was unable to resume
professional activities until 1 January 2025. The Claimant contended that the Club’s
unilateral termination during his recovery period violated his “occupational stability” and
that he is therefore entitled to 12 months of salary.
10. Finally, he maintained that his claim was justified under the contractual obligations
between the parties, relying particularly on article 17.1 of the FIFA Regulations on the Status
and Transfer of Players (hereinafter: the Regulations).
11. In light of the above, the Player requested the following relief (quoted verbatim):
“1. In view of the above, it is requested:
a. the citation of the Respondent, wishing to present the defense within the legal term, under
penalty of default;
b. the reversal of the burden of proof in favor of the Claimant;
c. the deferral of this Claim to order the Respondent to pay for compensation, the total of US$
18.000,00 (US Dollars) to the Claimant, corresponding to the 12 months' salary that is entitled
the Claimant for the right of occupational stability that was not observed.”
b. Reply of the Club
12. In its reply dated 10 December 2025, the Club argued that the Player’s claim was
unfounded, as the Employment Contract did not end through a unilateral termination but
rather through the Termination Agreement signed by both parties on 21 April 2024.
According to the Club, this agreement was voluntarily executed at the Player’s own request
so that he could complete the final phase of his medical rehabilitation in his home country.
pg. 4
REF. FPSD-21908
The Club emphasized that the Player expressly released the Club from any further
contractual or financial obligations.
13. The Club further contended that it fully complied with all contractual obligations
throughout the Player’s injury period. It highlighted that it provided complete medical
support, paid for surgery and rehabilitation, and continued to pay the Player’s salary
without interruption.
14. Additionally, the Club argued that the Player provided no documentary evidence
supporting his allegations of unilateral termination, unpaid remuneration, or entitlement
to 12 months of salary. The Club also stressed that the Player’s reliance on “occupational
stability” had no basis in the Regulations and is not recognized as a compensatory
entitlement under the applicable framework.
15. Finally, the Club argued that even in a hypothetical scenario of unilateral termination, the
Player’s claim for USD 18,000 would still be unjustified. Under art. 17 of the Regulations,
compensation is limited to the residual value of the contract, which in April 2024 amounted
to only about one month and ten days. According to the Club, any compensation would
therefore be far below the amount claimed.
16. In light of the above, the Club requested the following relief (quoted verbatim):
“32. Therefore, for all the above reasons, the Respondent respectfully requests the Dispute
Resolution Chamber of the FIFA Tribunal to rule with the following:
i. To dismiss the Claimant’s claim in its entirety.
Subsidiarily, and only in the event that the DRC were to find that the Respondent unilaterally
terminated the Contract without just cause:
ii. To limit any compensation to the residual value of the Contract between 21 April 2024
and 31 May 2024.”
c. Replica of the Claimant
17. Despite having been granted the opportunity to submit a replica, the Player did not file any
submission in this respect.
pg. 5
REF. FPSD-21908
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
18. 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 13 November 2025 and submitted
for decision on 3 February 2026. Taking into account the wording of arts. 32 and 35 of the
January 2026 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.
19. 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 was competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Brazilian player and an Emirati club.
20. 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 was applicable to the matter at
hand as to the substance.
b. Burden of proof
21. 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
22. 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 was going to refer only to the facts, arguments and documentary
evidence, which he considered pertinent for assessing the matter at hand.
pg. 6
REF. FPSD-21908
i. Main legal discussion and considerations
23. 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 breach of contract.
24. On the one hand, the Player argued that the Club terminated his employment on 8 April
2024 without just cause. He claimed that he refused to sign the release document
presented by the Club because “the Club did not pay him anything.” In light of this, the Player
requested USD 18,000 in compensation, asserting that this amount represents 12 months
of salary to which he is entitled due to the “right of occupational stability that was not
observed” by the Club.
25. On the other hand, the Club argued that the Parties had mutually terminated the contract
on 21 April 2024 through the Termination Agreement, at the Player’s own request, after the
Club had fully complied with its medical and financial obligations during his injury. It also
argued that the Player presented no evidence of unilateral termination, unpaid salary, or
any entitlement to 12 months of remuneration, and that “occupational stability” is not
recognized under the Regulations. The Club further noted that, even in a hypothetical
scenario of unilateral termination, any compensation would be limited to the residual value
of the contract and not equal to the USD 18,000 claimed. It therefore requested that the
claim be dismissed or, alternatively, that any compensation be restricted to the residual
value of the contract.
26. In this context, the Single Judge acknowledged that his task was to assess the
circumstances of the termination of the Employment Contract, as well as the consequences
arising therefrom.
27. Firstly, the Single Judge observed that, although the Player claimed that the Club
terminated the Employment Contract without just cause and that he refused to sign the
proposed termination document, the Club submitted a fully executed version of the
Termination Agreement indicating that both parties mutually agreed to terminate the
contract and that the Player released the Club from any financial obligation towards him.
28. In this connection, the Single Judge highlighted that the Player was given the opportunity
to contest the authenticity or validity of this signed Termination Agreement through a
replica, but ultimately chose not to submit any objection. Consequently, the signed version
of the Termination Agreement presented by the Club remained uncontested in the case
file.
29. Similarly, the Single Judge noted that the Player did not contest the salary payment
evidence submitted by the Club, nor did he provide any elements that would justify
deviating from the terms of the signed Termination Agreement presented by the Club.
pg. 7
REF. FPSD-21908
30. In view of the above and based on the documents available in the case file, the Single Judge
concluded that the Employment Contract was terminated by mutual agreement through
the Termination Agreement signed on 21 April 2024. Accordingly, the Single Judge decided
to reject the Player’s claim for compensation for breach of contract.
d. Costs
31. 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.
32. 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 would be
awarded in these proceedings.
33. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 8
REF. FPSD-21908
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Antonio Carlos Soares Melo, is rejected.
2.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 9
REF. FPSD-21908
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