City can point to the disrepute Balotelli has brought upon the club and manager Roberto Mancini's persistent attempts to tackle a disciplinary record which saw the striker miss 11 of the club's 54 games - 20.37pc - of last season.
The Premier League champions, who ascribe huge importance to the way players' conduct reflects on the positive image of the club, will argue the 22-year-old Italian is in breach of his own contract when they face him at a Premier League tribunal in London tomorrow.
But experts in the field believe that the PFA/Premier League guidelines - which only allow clubs to fine players for a sequence of dissent and violent conduct charges - will take precedence over the contract.
City are confident they will win their highly unusual case against Balotelli, whom they fined at the end of last season because of a pattern of on-field behaviour. But even if the two-man tribunal rejects Balotelli's appeal, the player can take it to a Football League appeals committee, dragging the public dispute into next year.
Potentially the legal case could stretch beyond his career at the Etihad, if this public spat does prove the last straw.
City went outside PFA and Premier League guidelines last season, when they attempted to fine Carlos Tevez four weeks wages, later reduced to two, after the PFA backed the striker.
This time, Balotelli's lawyers are expected to draw on the disciplinary template agreed several years ago relating to "field discipline."