Executive Summary: Key Legal and Evidentiary Issues

• Club des Braves d'Ahuntsic was declared the forfeit loser of a May 4, 2025 match and fined $500 after Soccer Québec determined it had exceeded the maximum number of permitted players in the technical zone.
• Procedural fairness was the central issue, with the Club alleging multiple violations throughout Soccer Québec's administrative, revision, and appeal decision-making processes.
• Soccer Québec contested the Superior Court's jurisdiction, arguing the dispute concerned the application of rules of play rather than a reviewable matter of procedural law.
• At issue was whether the May 5, 2025 email from the opposing team's general director constituted a formal protest (protêt) under the applicable regulations, which would have triggered additional procedural protections for the Club.
• The Appeal Committee's decision was challenged for alleged bias and for relying on information — including references to fraud and concealment — that the Club argued fell outside the Appeal Committee's jurisdiction.
• Ordering the Club's integration into the 2026 season of the Première Ligue de Soccer Juvénile du Québec was sought as a remedy, but the Court found the loss-of-chance argument too speculative to support such an order.

Facts of the case

On May 4, 2025, Club des Braves d'Ahuntsic (the Club), competing in the Ligue de développement provincial (LDP) of the Fédération de Soccer du Québec (Soccer Québec), played and won a match against Révolution FC, with a final score of 3–1. On May 7, 2025, Samuel Grenier, Coordinator of Competitions at Soccer Québec, notified Eduard-Nick Pascalau, the Club's General Director, that an investigation had concluded the Club had exceeded the eligible number of players in the technical zone and that players were absent from the match sheet. As a result, the Club was declared the forfeit loser and fined $500 (the Administrative Decision). This outcome dropped the Club to second place in the LDP standings, preventing it from participating in the end-of-season provincial final, which was reserved for the first-place team.

The Club appealed the Administrative Decision to Soccer Québec's Revision Committee, which on May 14, 2025 upheld both the sanction and the fine, finding that the Club had violated Article 16.1 of the LDP regulations by having a total of 20 players take part in the match, when the maximum permitted was 18 (the Revision Decision). On May 28, 2025, the Club filed a further appeal before Soccer Québec's Legal Committee (Comité juridique), raising three grounds: (1) the absence of a duly filed protest (protêt) under the regulations; (2) a denial of procedural fairness before the Revision Committee; and (3) in the alternative, the excessive severity of the sanction. On August 5, 2025, the Legal Committee, deciding on the record without holding a hearing, upheld the Administrative Decision and the $500 fine (the Appeal Decision). The Club then filed a judicial review application on September 9, 2025, subsequently amended, seeking to quash the Appeal Decision, restore the original match result, and obtain an order integrating the Club into the 2026 season of the Première Ligue de Soccer Juvénile du Québec (PLSJQ) in the U-16 category.

Regulatory provisions at issue

Several provisions of Soccer Québec's internal regulations were central to the dispute. Article 16.1(j) of the LDP regulations provides that a team forfeits a match if it has more than 18 players on the match sheet and/or on the field and in the technical zone, whether in match uniform or not. Under Article 7.1 of the Regulations on Discipline and Appeal Procedures (RDPA), a protêt is defined as a contest submitted by a team regarding the final result of a match, aimed at changing its outcome. Article 32.2 of the Rules of Procedure (RF) sets out the formal requirements for a protêt, including that a copy must be sent to the opposing club within the same deadline, and Article 32.3 RF requires that the filing be accompanied by a deposit of $150. Article 8.1(a) RDPA distinguishes an administrative decision — any decision, other than a disciplinary or protêt decision, affecting the rights of a person or team — from a protêt decision, noting that both tracks carry internal recourse mechanisms. Article 2.2(b)(ii) RDPA confers exclusive jurisdiction on the provincial Discipline Committee in cases of fraud or concealment in registration, transfer, or similar proceedings.

Reasoning and analysis

The Court first confirmed its jurisdiction, noting that under Article 34 of the Code of Civil Procedure, the Superior Court holds a general power of judicial review over private legal persons, including non-profit organizations. While courts cannot rule on the application of rules of play — such as decisions made by referees during a match — judicial review is available where a private sports entity's internal decision-making process is regulated and the decision emanates from a domestic tribunal raising issues of procedural fairness. Because the Club's challenge targeted the transparency and regularity of Soccer Québec's decision-making process rather than a referee's in-game ruling, the Court found it had jurisdiction.

On the applicable standard, the Court confirmed that intervention is warranted only in exceptional cases — where the decision is arbitrary, tainted by a fatal irregularity, or constitutes a denial of procedural fairness — and that no deference is owed to the decision-maker on questions of procedural fairness.

The Court then addressed the Club's central argument that the May 5, 2025 email from Révolution FC's General Director, Mous Sall, constituted a protêt that should have been disclosed to the Club and triggered a hearing. The Court found it did not. While the email bore some characteristics of a protest — it was official in tone and came from the opposing team's general director — it failed to comply with the mandatory procedural requirements of Article 32.2 RF: no copy was sent to the Club, and no $150 deposit accompanied it. The Court found this was not a mere technical defect; the deposit is integral to the protêt process. Soccer Québec's decision to treat the email as information and proceed by way of administrative decision rather than the protêt route was not a breach of procedural fairness, particularly since both tracks provide internal recourse mechanisms.

On the Administrative Decision itself, the Court found that Grenier, in his capacity as LDP Competition Coordinator, had the authority to render the decision and was responsible for enforcing the administrative regulations. Regarding the Revision Decision, the Court acknowledged that Soccer Québec had imposed an unjustified deadline of May 12, 2025 at 9:00 a.m. — rather than the 15-day period required under Article 8.2(b) RDPA — for the Club to file its challenge before the Revision Committee. The Appeal Decision itself had already recognized this error. However, the Court agreed with the Appeal Decision's finding that the Club suffered no prejudice, as it was ultimately able to present all three grounds of appeal in its written submission to the Legal Committee.

Regarding the Appeal Decision, the Court rejected the Club's claims of bias and misleading conduct. Me Audrey Baillairgé, acting on behalf of the Legal Committee, had reviewed the entire file with care, asked pointed questions about the procedural irregularities, and considered the Club's arguments — including those concerning the Revision Committee's errors. The Court found that the responses provided by Guégano, Soccer Québec's Director of Administrative Operations, did not establish undue influence over the Legal Committee's deliberations. As the Club did not contest having committed the underlying infraction, the Court also found that the absence of the referee's formal report from the Legal Committee's file was immaterial. The Court further rejected the argument that the Legal Committee lacked jurisdiction merely because its decision referenced "concealment" and "fraud": the exclusive jurisdiction of the provincial Discipline Committee under Article 2.2(b)(ii) RDPA applies only to fraud or concealment in registration, transfer, or similar proceedings — not to a game-day default of the type at issue here. Moreover, by filing its appeal before the Legal Committee, the Club had submitted to that body's jurisdiction.

On the Club's request for integration into the PLSJQ's 2026 season, the Court held that this relief could not be granted. The Club's theory rested on a loss-of-chance argument: absent the Administrative Decision, the Club would have led the LDP standings with 43 points (compared to Révolution FC's 37), qualified for the four-team provincial final, and potentially earned promotion. The Court found this chain of events — from participation in the final to ultimate qualification for the PLSJQ — amounted to a mere possibility rather than a real and serious probability. Established jurisprudence recognizes loss of chance as a basis for monetary damages, not as a ground for a mandatory injunction of the kind the Club was seeking.

Ruling and overall outcome

The Court dismissed the Club's judicial review application in its entirety. The Fédération de Soccer du Québec prevailed as the successful party, with costs awarded against the Club. No specific monetary amount for costs was stated in the judgment; the only fixed monetary figure referenced throughout the proceedings was the $500 fine originally imposed by Soccer Québec's Administrative Decision, which the Court declined to disturb.