Me Belmahi: The Senegalese Football Federation Caught by the CAF Regulations and Statutes
By: Mohammed Tafraouti
In a recent legal analysis, Maître Mohamed Belmahi explained that the appeal lodged by the Senegalese Football Federation (FSF) before the Court of Arbitration for Sport (CAS) is procedurally inadmissible. Indeed, the Senegalese Federation failed to exhaust the internal remedies provided for under the statutes of the Confederation of African Football (CAF). It chose not to challenge the decision of the Disciplinary Committee at first instance, despite having been legally notified. The expiration of the statutory deadlines therefore automatically results in the forfeiture of its right to appeal before the CAS.
Dr. Belmahi emphasizes that the role of the CAS is not to re-examine the dispute on the merits or reassess the facts, but rather to ensure compliance with legal procedures and to guarantee the strict application of the regulations governing competitions. In this respect, the Tribunal functions in a manner similar to a Court of Cassation: it focuses on the regularity of the procedure, the respect of deadlines, and the protection of the rights of the defense, without necessarily re-evaluating the facts or altering match results.
In this case, the CAF Appeals Jury reviewed the file and issued its decision on 17 March 2026, which has since acquired a final character within the internal procedures of the continental confederation.
This legal position is supported by explicit provisions, notably Article 91.4 of the CAF Disciplinary Code, which stipulates that decisions of the Disciplinary Committee are immediately enforceable unless an appeal is lodged before the Appeals Jury. In addition, Articles 82 and 84 of the Africa Cup of Nations Regulations define the sanctions relating to match forfeiture or abandonment.
The legal analysis also relies on a major precedent in African sports litigation: the case opposing Wydad Athletic Club (WAC) to Espérance Sportive de Tunis (EST) during the 2018–2019 CAF Champions League final. In an official statement issued in Lausanne on 18 September 2020, the CAS confirmed the CAF decision declaring the Moroccan club to have lost by forfeit after its refusal to resume the second leg of the match, which had been interrupted in Radès. The arbitral panel considered that the decision by Wydad players not to continue the match constituted a clear abandonment, thereby justifying the forfeit defeat in accordance with the CAF Disciplinary Code.
In light of these elements, Maître Belmahi concludes that the action brought by the Senegalese Federation before the CAS remains procedurally inadmissible due to its failure to meet the requirement of exhausting CAF’s internal remedies. Consequently, the decision of the CAF Appeals Jury—thoroughly and convincingly reasoned—remains final and enforceable, and the sanction of a forfeit defeat imposed on the Senegalese national team should therefore be confirmed by the CAS.
It is also worth noting that, contrary to the position of the Royal Moroccan Football Federation, the inconsistency in the stance of the Senegalese national team is striking. The team repeatedly argued that a match should be won on the field of play, yet it now turns to the CAS in an attempt to win it at the green table.
Go figure!
It should be noted that Maître Mohamed Belmahi is a lawyer at the Meknès Bar and holds a doctorate specializing in sports law. His analysis benefits from sharp legal expertise combined with a thorough understanding of the organizational framework of sport.
