Igor Strelkov ANP 2500

How Igor Strelkov made training alone in Russia illegal

Employment Status Case study

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Igor Strelkov ANP 2500
Igor Strelkov fought against the practice of training alone. He objected to his club’s order to daily train in the cold Russian winter while the rest of the team was at training camp in Turkey and Spain. Strelkov won his case and the Russian Football Association declared training alone illegal.

How it unfolded

Strelkov signed a three-year contract with FC Krylia Sovetov in March 2010. On 22 January 2011, the club and player agreed that he could leave training camp to find another club. But Strelkov was unable to find a new club before the international transfer market closed on January 31st.

FC Krylia then ordered Strelkov to daily train in compliance with an individual training programme, which consisted of practising at least three hours in the cold Russian winter. At the same time, his teammates were in training camps in Turkey and Spain.

Strelkov refused. He demanded that he could train with his team. His refusal caused a bigger conflict with the club, which did not register the striker for the about-to-start championship.

After a legal battle in Russia, both parties ended up at the international sports tribunal, CAS.



CAS decided in February 2012 that Strelkov could not be forced to train separately, stating it is a basic player’s right to train with the squad.

FC Krylia had to pay Strelkov a compensation for unlawful breach of contract and for arrears, as the club had refused to pay him while he was sick.


Why is this verdict so important?

Following his case, the Russian FA amended its regulations, recognizing training alone as a substantial infringement on the labour agreement.

The amendments prohibit ‘discrimination during the training period by way of unfounded (not based on medical necessity) long training sessions “without a ball” or aside of the club’s first squad training sessions, as well as an unfounded longstanding absence of training sessions’.


Photo: Igor Strelkov (left) as a player for FC Moscow