Sports lawyer Dan Chapman told TEAMtalk that Manchester City might pursue further legal action against the Premier League over the independent commission's decision, possibly escalating the case to the High Court.

The Premier League confirmed on Tuesday that the independent commission found Manchester City guilty of most of the previously alleged financial rule breaches and also found that Manchester City failed to cooperate with the investigation. Premier League documents show that Manchester City was accused of inflating revenues by approximately £900 million, which represents bad news for the club.
It is reported that Manchester City's legal team, led by Lord Pannick, has begun preparing an appeal ahead of the October 2 deadline.
Sports lawyer Dan Chapman said: "Given the statement made by CEO Soriano on behalf of Manchester City, I think it's reasonable to conclude that Manchester City will seek to challenge the independent commission's decision – both on the finding of liability and on any eventual penalty – and will take that challenge to the High Court."
Premier League rules require such disputes to be resolved through an agreed arbitration process, but in certain limited circumstances, an arbitration award can still be challenged in court.
Chapman believes that Section 68 of the 1996 Arbitration Act might provide Manchester City with a potential path forward.
He stated: "Firstly, Premier League clubs have, by the rules of the League, agreed that such disputes can only be resolved using the agreed arbitration process. However, as with any arbitration case – whether in sport or otherwise – there is a very narrow gateway to allow an arbitrated matter to go into a more public court process."
He explained: "The most likely gateway, and perhaps one that can be read from Manchester City's current statements, is what is called a Section 68 challenge. In simple terms, it means a party alleges that there was a serious procedural irregularity in the arbitration award, and that irregularity caused substantial injustice."
However, the threshold for making such a challenge is extremely high. Chapman further explained: "The threshold is very high. It's not enough to simply demonstrate some procedural error, or that Manchester City thinks the commission did a poor job of understanding a vast amount of evidence."
Manchester City has previously attempted to use this route to challenge the Premier League in the High Court.
In 2021, Manchester City challenged an arbitration award concerning a previous procedural stage of this case on the grounds that the appointment of the arbitrator lacked impartiality. However, Manchester City was ultimately unsuccessful.
Newcastle United also challenged the appointment of an arbitrator in the High Court in 2021, but also failed.
However, there are precedents for successful Section 68 challenges in football.
Chapman mentioned the case of AFC Fylde v Fleetwood Town. In that case, Fleetwood successfully persuaded the High Court to overturn an arbitration award due to serious procedural irregularities during the arbitration process.
Chapman said: "That was mainly because, after the arbitration hearing, evidence emerged that the arbitrator had been corresponding with the FA about the scope and content of FA rules without informing the parties to the case or allowing them to comment on the issues."
However, such cases remain extremely rare.
Chapman concluded: "Given how long the Manchester City arbitration process has gone on, and the fact that both sides have very strong legal teams involved, and given that I have read the detailed findings set out in the core award, it's hard to imagine Manchester City successfully challenging in the High Court.
"From Manchester City's current statements, they seem entirely unreceptive to such pessimism, or what some might call realism. Therefore, I think that in addition to all other avenues they can pursue – including appealing the independent commission's decision on liability and appealing any penalties later – we can now expect that Manchester City's challenge to the High Court will be inevitable."
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