Quick answer
In Yokuşlu v. Türkiye (no. 489/24, 6 January 2026), the European Court of Human Rights held unanimously that there had been a violation of Article 6 § 1: notwithstanding the legislative reform that followed earlier judgments, the safeguards surrounding the Arbitration Committee of the Turkish Football Federation remained insufficient in practice to secure its independence and impartiality.
Background and facts
The applicant, a professional footballer born in 1999, played for a club then competing in the Turkish First League. In May 2023 his lawyer served formal notice that the contract would be terminated thirty days later if outstanding salary was not paid. The club paid in June 2023, but the applicant did not inform his lawyer, who filed a termination notice with the Federation in July 2023. The Federation registered the termination and cancelled the applicant’s registration with the club; an attempt by the applicant’s lawyer and the club to retract the notice followed.
The dispute was determined within the Federation’s own structures, with the Arbitration Committee deciding at final instance. Before the Court the applicant complained about the independence and impartiality of that committee, his right of access to a court, the right to a reasoned decision and his private and family life.
The Court’s reasoning
The Court’s summary of the judgment records continued deficiencies in practice and a lack of sufficient safeguards, despite the improvements introduced by legislative reform. That formulation is the heart of the case: a reform that changes the statutory description of a body does not by itself change how the body is appointed, controlled and able to act. Article 6 § 1 is concerned with the guarantees that operate in reality.
Having found the violation on that ground, the Court held that there was no need to examine the remaining complaints under Article 6 § 1.
The judgment
- Unanimously, the complaints under Article 6 § 1 were declared admissible and the remainder of the application inadmissible.
- Unanimously, a violation of Article 6 § 1 on account of the lack of independence and impartiality of the Arbitration Committee.
- Unanimously, no need to examine the remaining Article 6 § 1 complaints.
- EUR 6,000 for non-pecuniary damage and EUR 3,000 for costs and expenses.
What this means for athletes and counsel
Two points carry across to other disputes. First, a finding of a structural violation does not expire when the State amends the law: the question is whether the safeguards work, and that has to be shown on evidence about practice. Second, the judgment was decided on the independence ground alone, leaving the access-to-court and reasoning complaints unexamined — a reminder that pleading several Article 6 limbs is useful precisely because the Court may dispose of the case on one of them.
On the same day the Court delivered Altıner Akıncı v. Türkiye (no. 9570/23), concerning the Turkish Volleyball Federation’s Sports Arbitration Board, where it found no violation on the independence limb but a violation on account of insufficient judicial review. The pairing shows that each safeguard is assessed separately. How these findings are used in an individual case is set out on our sports arbitration page.
Convention Articles engaged
Cases against this state
Related ECHR cases
- Ali Rıza and Others v. Turkey: Independence of Football Arbitration
- Semenya v. Switzerland: Article 6, CAS Arbitration and Swiss Judicial Review
- Mutu and Pechstein v. Switzerland: Fair Hearing in Sports Arbitration
- Străin and Others v. Romania
- Brumărescu v. Romania
- Rotaru v. Romania
Facing a similar case?
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Read the full judgment on HUDOC (official ECHR database)
Frequently Asked Questions
How does this differ from Ali Rıza?
Ali Rıza and Others (2020) identified the structural problem and required general measures. Yokuşlu examined the position after reform and found the safeguards still wanting in practice.
Does the judgment reinstate the contract?
No. The Court decides State responsibility and may award just satisfaction; it does not restore a registration or rewrite a contract. Domestic consequences depend on national law and on execution of the judgment.