Labour Disputes
Texto da decisão
REF. FPSD-18291
Decision of the
Dispute Resolution Chamber
passed on 20 June 2025
regarding an employment-related dispute concerning the Player Roland
Teddy Okouri
COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Stefano SARTORI (Italy), Member
Andre DOS SANTOS MEGALE (Brazil), Member
CLAIMANT:
Roland Teddy Okouri, Congo
Represented by Talel Ben Hadj
RESPONDENT:
El Tallaeaa Regdaleen, Libya
pg. 2
REF. FPSD-18291
I. Facts of the case
1.
On 2 November 2024, the Congolese player, Roland Teddy Okouri (hereinafter: the Player
or the Claimant) and the Libyan club, El Tallaeaa Regdaleen (hereinafter: the Club or the
Respondent) allegedly concluded an employment contract (hereinafter: the Alleged Contract)
valid as from 15 November 2024 until the end of the 2024/2025 season. The Alleged
Contract contained the Player’s signature; however it did not contain the Club’s signature.
2.
In accordance with the Alleged Contract, the Player was entitled to a total contract value
of USD 11,000.
3.
According to the Player, the Club issued a flight ticket for him on 13 December 2024.
4.
According to the Player on 3 January 2025, the Player was informed that the Alleged
Contract had been unilaterally terminated by the Club.
5.
According to the Player, on 8 January 2025, the Club provided a flight ticket to Player.
6.
On 8 January 2025, the Player sent an email to the Club, informing them that they were
unilaterally terminating the Contract and requesting them to rectify the situation within 24
hours.
7.
According to the Player, he was accompanied by the Club’s President to the airport on 9
January 2025, and he arrived in Brazzaville on 10 January 2025.
8.
It was noted that there was no registration of the Player’s transfer to the Club in the
Transfer Matching System (TMS).
II. Proceedings before FIFA
9.
On 19 February 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Claimant
10. In his claim, the Player argued that the parties had a valid contract, however the Club did
not provide a signed copy of it. Moreover, he mentioned that “ the Club’s stance changed
upon the Player's arrival in Libya, where they failed to provide a signed contract or even request
a CIT (Confirmation of International Transfer) from the Player. This failure should not be used to
the benefit of the Club. The non existed between the Player and the Club. The contract’s existence
is not in question.
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REF. FPSD-18291
Moreover, the Club’s official Facebook page of the club has published a photo of the
Player on and confirmed that he arrived in Libya to join the Club for the new season.
This confirms the Player's intent to fulfill his contractual obligations and represents a
public acknowledgment of the contract’s validity.”
11. The Claimant further stated that the Respondent terminated the Alleged Contract without
just cause.
12. The Claimant requested the following relief:
“1. The Club unilaterally terminated the employment contract without just cause, violating
Articles 13 and 14.1 of the FIFA RSTP
2. The Club failed to meet its financial obligations, violating Article 12bis of the FIFA RSTP.
C. Claims for Relief
The Player requests the FIFA DRC to order the Club to pay the following amounts:
1. Outstanding Salaries:
$3,000 (signing fee),
Total: $3,000, plus 5% interest from the relevant due dates.
2. Compensation for Breach of Contract:
The Player is entitled to compensation for the remaining value of the contract, totaling
$8,000, plus 5% interest from the date of termination until payment is made.
Total Claim:
$3,000 as outstanding salaries, plus interest.
$11,000 as compensation for breach of contract, plus interest.”
b. Position of the Respondent
13. Despite being invited, the Respondent failed to provide its position to the claim.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
14. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or DRC) analysed
whether it was competent to deal with the case at hand. In this respect, it took note that
the present matter was presented to FIFA on 19 February 2025 and submitted for decision
on 20 June 2025. Taking into account the wording of art. 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.
15. Furthermore, the Chamber 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
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REF. FPSD-18291
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (January
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 Congolese player and a Libyan club.
16. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 29 of the
Regulations, the January 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
17. The Chamber 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 Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it 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
18. Having established the competence and the applicable regulations, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all
the above-mentioned facts as well as the arguments and the documentation on file.
However, the Chamber emphasised that in the following considerations it will refer only to
the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
19. The foregoing having been established, the Chamber moved to the substance of the
matter, and took note of the fact that this is a claim of a Player against a Club concerning
an alleged termination of the employment relationship.
20. The Chamber started by recalling that the Claimant stressed that the parties had a valid
and binding contract, and that the Respondent terminated it without just cause.
21. Equally, the Chamber observed that the Respondent did not respond to the claim, entailing
that the Chamber’s decision must be made on the basis of the documentation on file, that
is, the argumentation and evidence filed by the Claimant in line with art. 14 par. 1 and 21,
par. 1 of the Procedural Rules.
pg. 5
REF. FPSD-18291
22. The Chamber also observed the copy of the Contract provided by the Player did not contain
the Club’s signature. In this context, the Chamber acknowledged that its task was to first
determine whether the parties had a valid and binding Contract.
23. The Chamber started by recalling the Football Tribunal well-established jurisprudence
which dictates that, in order for an employment contract to be considered as valid and
binding, apart from the signature of both parties or any other proof of consent, it should
contain the essentialia negotii of an employment contract, such as the parties to the
contract and their role, the duration of the employment relationship and the remuneration
payable by the employer to the employee.
24. The Chamber further recalled that the signature of a contract by both parties is an
important element in order to establish an employment relationship, essentially because
this is the easiest way to demonstrate mutual consent. However, having an unsigned
specimen of the contract does not automatically mean there is no employment
relationship between the parties, because this shall be established on a case-by-case basis
and considering the entirety of the facts of the case and the elements at the disposal of the
deciding authority.
25. Furthermore, the Chamber recalled that a party that asserts a fact has the burden of
proving it (cf. art. 13 par. 5 of the Procedural Rules).
26. In assessing the matter, the Chamber noted the following:
-
The alleged Contract did not bear the Club’s signature.
-
There was no evidence demonstrating how the Player had received a copy of the
Contract.
-
A flight ticket reservation in the name of the Player from Brazzaville to Tripoli
dated 11 December 2024, with arrival on 13 December 2024, was submitted.
However, there was no evidence as to how the Player had received this document.
-
A return flight ticket reservation in the name of the Player from Tripoli to
Brazzaville dated 9 January 2025 was also submitted, again without any indication
of how the Player had received it.
-
A social media post, allegedly from the Club’s official account, contained the
following message: “Captured on the morning of Friday, December 13, 2024, the
moment of arrival of the two professional players from the Democratic Republic of
Congo at Mitiga International Airport to join our first team. Wishing our club success,
God willing, in the upcoming sports events.” The referenced post included a photo
of three individuals; however, no name could be linked to the Player.
pg. 6
REF. FPSD-18291
27. In view of the foregoing, the majority of the Chamber found that there was no evidence
indicating how the Player had obtained a copy of the Contract, whether it had been sent
by the Club, whether the Player had accepted its terms, or whether the referenced social
media post indeed referred to him. The Player submitted a flight reservation; however,
there was no indication of who had booked or paid for the tickets. Furthermore, the date
of arrival in Libya did not correspond with the alleged commencement date of the Contract.
The Player also claimed that the Club had informed him of the termination of the Contract,
but no supporting evidence was provided in this regard.
28. In light of the above, the majority of the Chamber found that the Player had not provided
sufficient evidence to establish the existence of a valid and binding employment contract
between the parties and consequently, the alleged termination of the Contract.
29. Consequently, the majority of the Chamber decided to reject the claim in its entirety.
d. Costs
30. The Chamber 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 Chamber decided that no procedural costs were to be
imposed on the parties.
31. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
pg. 7
REF. FPSD-18291
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Roland Teddy Okouri, is rejected.
2.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 8
REF. FPSD-18291
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
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