LET'S TALK SPORTS LAW

[Author: Saksham Agrawal, Law Student at NLSIU, Bengaluru, India]

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Introduction

The Court of Arbitration for Sport (“CAS”) has admitted the Senegal Football Federation’s (“Senegal”) appeal against the decision of the Confederation of African Football (“CAF”), noting that it is “perfectly equipped to resolve this type of dispute.” The case arrives there in unusual circumstances. CAF’s decision to overturn the result of the 2025 Africa Cup of Nations final and award the title to the Moroccan Football Federation (“Morocco”) was taken weeks after the match had been played to completion and formally recognised. It is one of the more unusual interventions in recent football governance.

Football’s regulatory structure does not treat all decisions in the same way. The Laws of the Game place control of the match in the hands of the referee, whose decisions govern both its conduct and its conclusion. Alongside this sits a separate layer of regulation, under which governing bodies enforce disciplinary rules and may impose sanctions after the fact. The difficulty in the present case is that the two do not operate neatly apart. The match was interrupted, but resumed and completed under the referee’s authority. CAF’s decision proceeds on the basis that, notwithstanding that completion, the same sequence of events constituted a forfeiture.

The question is not simply whether a rule was breached, but how that breach is to be understood in light of what followed. A match that is abandoned presents one set of legal consequences; a match that is completed presents another. The attempt to treat the latter as the former is what gives the dispute its character. Senegal’s appeal, therefore, is directed as much at the classification of the event as at the sanction imposed. What CAS is asked to decide, in substance, is how far regulatory authority extends once a match has been played to its end. That inquiry does not lend itself to a purely textual answer. It requires an assessment of how the rules operate within the structure of the game, and of the point at which intervention ceases to enforce that structure and begins to unsettle it.

This article examines the potential grounds upon which Senegal may challenge CAF’s decision before CAS, and considers how CAS is likely to approach the dispute within the framework of established jurisprudence. It argues that while CAF possesses undoubted authority to sanction misconduct, the retroactive conversion of a completed match into a forfeiture sits uneasily with the doctrine of the field of play, the principle of legal certainty, and the proportional limits of disciplinary intervention.

Factual and Regulatory Background

The dispute arises from the AFCON 2025 final, where a late penalty awarded to Morocco prompted a temporary walk-off by Senegal in protest. The referee, however, did not end the match but instead, he permitted a restart, and the match was played to completion, with Senegal securing victory after extra time. The result was recorded and the title awarded accordingly.  Following the match, Morocco filed a complaint the very next day before the CAF Disciplinary Board seeking, among other reliefs, the reversal of the match result in its favour alleging breaches of Articles 82 and 84 of the AFCON Regulations. Articles 82 and 84 of the AFCON Regulations provide that a team leaving the field without authorisation may be deemed to have forfeited the match, triggering an automatic 3–0 loss.

On 28 January 2026, the CAF Disciplinary Board held that Senegal’s temporary walk-off constituted unsporting conduct and imposed substantial financial penalties, amounting to approximately USD 715,000 across players, officials, and Senegal. Morocco was likewise sanctioned, with fines totalling around USD 415,000 arising from separate instances of misconduct involving players, officials, and match personnel. Morocco proceeded to appeal the decision to the CAF Appeal Board on 3 February 2026.

On 17 March 2026, CAF’s Appeals Board invoked Articles 82 and 84 of the AFCON Regulations to reverse the Disciplinary Board’s decision. They characterised the walk-off as a refusal to play and retrospectively awarded      Morocco a 3–0 victory.      

This sequence engages multiple legal frameworks, namely, Law 5 of the IFAB Laws of the Game, which vests authority in the referee to manage and conclude matches; CAF’s disciplinary provisions governing forfeiture; and the broader corpus of CAS jurisprudence, which mediates the relationship between on-field finality and post-match regulatory intervention within lex sportiva.

The dispute turns on the relationship between two forms of authority that do not always sit comfortably together. Decisions taken during the match, particularly those of the referee, govern how the game is played and how it concludes. These are generally treated as final, not because they are always correct, but because the game cannot function if they remain open to continuous revision. Alongside this sits a separate layer of regulation, under which governing bodies assess conduct and impose sanctions after the match has ended.

The present case sits quite awkwardly between the two. CAF has not sought to revisit any individual decision made during the match. The penalty, the restart, and the eventual result remain untouched as matters of officiating. The difficulty arises from the characterisation of Senegal’s conduct. By treating the walk-off as triggering forfeiture, CAF does not alter any particular decision within the match, but instead displaces the result that those decisions collectively produced.

This brings the issue into focus. The question actually arising is whether the ‘rules’ can be applied in a manner that effectively converts a completed match into one that is treated, in law, as if it had not been validly played. That move sits uneasily with the logic that gives referee decisions their finality in the first place.

Potential Grounds for Senegal’s Appeal before CAS

Mischaracterisation of “Refusal to Play”

The starting point of Senegal’s appeal is the meaning of “refusal to play” under Article 82. The provision is framed broadly, but it does not operate in abstraction. Its application depends on how the conduct in question is properly characterised. A distinction must be maintained between conduct that brings a match to an end and conduct that interrupts it but is later resolved. The two are not equivalent, and the regulation does not clearly treat them as such.

It is not disputed that Senegal left the field without authorisation. What is contested is the legal character of that act when viewed in context. The players returned, the referee permitted the restart, and the match was carried through to extra time and conclusion. Those events do not sit easily with the idea of a refusal to play. They suggest, instead, a disruption that was ultimately absorbed within the match itself.

Reading Article 82 as covering any unauthorised departure, regardless of what follows, stretches the provision beyond its evident function. Forfeiture rules are generally directed at situations where a match cannot be completed. They address breakdown, not interruption. To treat a temporary walk-off followed by compliance as equivalent to abandonment risks detaching the rule from the purpose it serves within the competition structure.

On that footing, Senegal’s conduct is more coherently understood as misconduct within the match rather than a refusal to participate in it. The difference matters. Misconduct attracts sanction while abandonment carries the consequence of forfeiture. Treating the two as interchangeable expands the reach of Article 82 beyond what its structure can comfortably bear.

Primacy of Referee Authority and the Field of Play Doctrine

The second line of argument turns on the legal effect of the referee’s decision to continue the match. Law 5 vests the referee with control over the conduct of play, including the decision to suspend or abandon proceedings. That authority reflects the premise that the match must, where possible, be resolved within its own framework.

In this instance, the referee did not treat the situation as one requiring abandonment. He allowed time for the players to return, authorised the restart, and oversaw the completion of the match. That sequence indicates how the incident was treated within the match itself, and it shapes how it can later be characterised.

The field of play doctrine reflects the principle that decisions taken by match officials during the course of play are, in general, not subject to review, in order to preserve the finality of sporting outcomes. It does not however place such decisions beyond all scrutiny, as CAS recognises a high threshold for interference, limited to exceptional circumstances such as bad faith, arbitrariness, or corruption. The difficulty for CAF is that its decision does not merely sanction conduct but displaces the outcome that the referee’s decisions produced.

The argument, properly framed, is not that the referee’s decision is immune from any subsequent consequence. It is that the decision to resume and complete the match is difficult to reconcile with a later finding that the same events amounted to abandonment. If the match was treated as capable of continuation at the time, the basis for treating it as irretrievably broken after the fact becomes less secure.

Retroactive Reclassification

The case also raises a more general question about the limits of post-match intervention. Disciplinary powers are not confined to the duration of play, but they do not operate in a vacuum. They sit within a system that depends on results having some degree of finality.

What is unusual here is not the imposition of a sanction, but the nature of it. The match was completed, the result recorded, and the title awarded. The subsequent decision does not simply penalise conduct; it alters the legal status of the match itself. It treats a completed contest as if it had, in effect, failed. That move has implications beyond the present case. If results remain open to reclassification after the fact, the stability of the competition is affected. Outcomes carry consequences that extend beyond the ninety minutes. Those depend on the assumption that completed matches are not lightly revisited.

There are situations where results are set aside, but they tend to involve clear breaches that undermine the competition at a structural level, such as eligibility or manipulation. The present case is different. The conduct occurred within the match, was managed within the match, and did not prevent its completion. Whether that is sufficient to justify erasing the result goes to the outer boundary of disciplinary authority.

Proportionality of Sanction

Even if it were to be accepted that Senegal’s conduct falls within the scope of Article 82, the question of sanction remains. Forfeiture of a final and reassignment of a title represent the most severe consequences available. They are ordinarily reserved for cases where the competition cannot produce a legitimate result.

CAS jurisprudence on proportionality has developed most prominently in doping cases, where the World Anti-Doping Code structures the sanctioning framework and leaves limited scope for independent proportionality review. The present case, however, arises in a disciplinary context, where CAS exercises de novo review and may assess whether the sanction imposed is proportionate to the conduct in question. In that setting, proportionality remains a relevant constraint, particularly where the sanction affects the sporting result itself. A breach does not, by itself, justify any sanction that follows from the text of a rule. The response must bear some relation to the nature of the conduct and its effect on the competition.

Here, the match was completed and produced a result. The interruption was significant, but it did not prevent the contest from being resolved on the field. That raises the question whether lesser sanctions such as fines, suspensions, or other disciplinary measures would have addressed the conduct without displacing the result. If forfeiture is imposed in circumstances where the match has been completed, the distinction between disruption and collapse begins to narrow. That, in turn, expands the reach of the most severe sanction beyond the situations for which it is ordinarily reserved.

Acquiescence and Conduct of the Opposing Party

A final, more limited, point concerns Morocco’s conduct once play resumed. The match continued with the participation of both teams and was carried through to its conclusion. That sequence may be taken to indicate acceptance, in practical terms, of the referee’s handling of the situation.

The relevance of this is not straightforward in this context, and regulatory enforcement does not depend on whether a team objected at the time. The point therefore cannot be pressed too far.

Its significance is more contextual. The match was not only completed under the referee’s authority, but completed with the involvement of both sides. That reinforces the sense in which the contest retained its character as a sporting event, rather than breaking down into a situation requiring external resolution. It adds to the difficulty of treating the match, after the fact, as one that was never properly played.

CAF’s Legal Position and Counterarguments

CAF’s position proceeds from a strict reading of Articles 82 and 84. The starting point is the unauthorised departure from the field. Once that occurs, the breach is treated as complete, and the consequence follows from the regulation itself. On this reading, Article 84 does not depend on how events unfold afterwards. The later resumption of the match may explain the context, but it does not undo the violation.

This approach rests on a separation between match control and competition regulation. The referee governs the match as it is played, including whether it should continue. CAF regulates compliance with the rules that structure the competition as a whole. From that perspective, the referee’s decision to resume the match does not determine whether a breach has already taken place. The walk-off is treated as a completed infraction, even if the match is subsequently brought to an end.

There is also a practical concern behind this position. A more flexible reading of Article 82 risks creating room for tactical disruption. If teams are able to leave the field, halt proceedings, and then return without facing the possibility of forfeiture, the incentive structure shifts. Walk-offs could become a means of contesting decisions or exerting pressure on officials. A stricter approach closes off that possibility by attaching a clear consequence to the act itself, irrespective of what follows.

CAF’s argument, therefore, is tied to how the rules are meant to function in practice, particularly in preserving the authority of match officials and limiting conduct that disrupts the continuity of play. This assessment, however, must remain provisional, given that only the operative decision has been made public and the full reasoning of the CAF Appeal Board has yet to be released.

Likely CAS Approach and the Role of Precedent

The resolution of the present dispute will turn less on abstract principle and more on how CAS chooses to characterise the events within its existing jurisprudence. The inquiry is structured around three related questions:

1. Whether Senegal’s conduct amounts to a “refusal to play” within Article 82
2. Whether a match that has been completed can nonetheless be treated as forfeited, and
3. Whether the sanction imposed can be sustained in light of the circumstances.

These are not independent issues. The classification of the conduct, in particular, will determine the scope of the remaining analysis. CAF’s position is most persuasive if the breach is treated as crystallising at the moment of the walk-off. On that view, subsequent events do not alter the legal consequence. The match may have been completed, but the violation had already occurred. That approach finds some support in the structure of Articles 82 and 84, which are framed in terms that do not expressly accommodate a distinction between temporary and definitive withdrawal.

The difficulty with that position becomes clearer when placed alongside prior cases. In the 2019 CAF Champions League final between Wydad Casablanca and Espérance de Tunis play broke down following a disputed VAR decision, prompting Wydad to refuse to continue and leave the field. The match did not resume, and the result was initially awarded to Espérance. CAF later attempted to order a replay at a neutral venue, a decision that was subsequently annulled by CAS on the basis that CAF had acted outside its disciplinary framework.

The case is instructive for two reasons. First, it confirms that regulatory intervention affecting results is closely tied to whether the match itself reaches completion. In 2019, it did not. Second, it illustrates CAS’s reluctance to endorse decisions that depart from established procedural structures, even where the underlying dispute is contentious.

The present case departs at precisely this point. Unlike in 2019, the match was not abandoned. The referee did not treat the walk-off as bringing the game to an end. Play resumed, the penalty was missed, and the match proceeded to its conclusion. That sequence complicates any attempt to treat the incident as functionally equivalent to the earlier case. Similarly, other matches where teams walked off but never returned have been characterised and officially awarded as a forfeit win to the other team. On the other hand, in the 1976 AFCON, during a match against Guinea, Morocco temporarily left the field in protest while trailing. The interruption did not bring the contest to an end. Play resumed, the match finished 1–1, and Morocco ultimately went on to win the tournament. No forfeiture followed, nor was the result disturbed after the fact.

These comparisons do not produce a single rule, but they do indicate a tendency. Where a match fails, forfeiture or annulment may restore order. Where a match is completed, the case for displacing the result is more difficult to sustain. The present dispute falls into the latter category, which places pressure on CAF’s attempt to characterise the events as abandonment.

That leaves open the possibility of a more limited conclusion. CAS may accept that Senegal’s conduct warranted sanction, while rejecting the step of converting a completed final into a forfeiture. This would allow the regulatory framework to operate without unsettling the result itself. It also aligns with the way CAS has, in practice, approached situations where the breach does not go to the existence of the match, but to the manner in which it was conducted.

A full affirmation of CAF’s decision would require CAS to adopt a strictly textual reading of Article 82, treating any unauthorised departure as sufficient to trigger forfeiture regardless of what follows. That outcome is not excluded, but it would mark a shift towards a more rigid approach than is typically reflected in cases involving completed matches. A full overturn, by contrast, would follow from a finding that the conduct did not meet the threshold of abandonment at all.

Between these positions lies the more likely path. CAS may reject the characterisation of the walk-off as a definitive refusal to play, while still recognising it as misconduct. That approach preserves the distinction between interruption and collapse, maintains the result produced on the field, and avoids extending forfeiture beyond the situations for which it is most clearly justified.

In that sense, the case is unlikely to be resolved through a purely literal reading of the regulations. It will turn instead on how those provisions are understood in practice, and on the weight given to the fact that the match, despite interruption, was played to its conclusion.

On the Jurisdiction of CAS

The appeal has been admitted by CAS, which suggests that no immediate jurisdictional bar has been identified. Nonetheless, jurisdiction remains a question that may be revisited during the proceedings, particularly if raised by a respondent or considered by the Panel as part of the merits.

The jurisdictional basis is found in Article 48 of the CAF Statutes, which provides for appeals to CAS against final decisions of CAF bodies, subject to certain limitations. There is no issue with the procedural requirement under 48(3) of filing within ten days of notification. More significant is the exclusion of CAS review in cases involving “violations of the Laws of the Game” under 48(4), a category that, if applicable, would place the dispute outside CAS jurisdiction.

That exclusion, however, is unlikely to be determinative in the present case. The dispute does not concern the correctness of any refereeing decision taken during the match, such as the award of a penalty or the application of the Laws of the Game or whether the referee erred by allowing the match to restart once Senegal left the field. Those matters fall squarely within the field of play doctrine and are not subject to review. The present appeal is directed instead at the subsequent decision of CAF to characterise Senegal’s conduct as constituting a forfeiture under Articles 82 and 84 of its Regulations. The issue is therefore one of regulatory interpretation and disciplinary consequence, rather than the application of the Laws of the Game as such.

Lastly, 48(7) further provides that an appeal to CAS does not have suspensive effect, with the impugned decision remaining in force pending the outcome of the proceedings. No provisional measures appear to have been sought or granted in this case, and the CAF Appeals decision therefore continues to operate unless and until it is set aside.

So while jurisdiction does not present an immediate obstacle, it remains to be seen whether it frames the scope of CAS review if CAF or Morocco decide to raise an objection against the jurisdiction of CAS. A jurisdictional objection grounded in the “Laws of the Game” exclusion would face difficulty, as it would require recasting a dispute over interpretation of forfeiture under Articles 82 and 84 as one concerning on-field officiating.

Broader Implications and Conclusion

The dispute here extends beyond the allocation of a title. It turns on how secure a result remains once a match has been completed. Competitions are organised on the assumption that outcomes reached on the field are not easily disturbed. If those outcomes can be revisited through later intervention, that assumption becomes less stable.

The case also tests how far disciplinary powers can reach after the match has ended. Misconduct can be sanctioned, but the present facts raise a narrower problem. The incident occurred during the match and did not prevent it from being completed. Treating that same incident as a basis for forfeiture requires a step beyond ordinary disciplinary action. It shifts the focus from regulating conduct to reclassifying the match itself.

The difficulty is sharpened by the way different sources of authority operate. The Laws of the Game govern how matches are played and concluded. Competition rules address compliance at a broader level. Where those two point in different directions, the question is not simply which applies, but how far one can displace the other without unsettling the structure they are meant to support. The case also forces a clearer account of interruption. Walk-offs are not unusual, but not every interruption amounts to abandonment. Where the match resumes and reaches its conclusion, the basis for treating it as failed becomes less certain. That distinction has not always been drawn with precision. This dispute requires it to be.

There is, finally, the question of how decisions of this kind are received. CAF’s approach has already attracted scrutiny. CAS is now required to assess not only whether the decision can be supported, but whether it fits within a system that depends on consistency and restraint. The answer will shape how similar situations are handled in future.

End of the day, the issue is whether completion still carries weight once a breach has occurred. If it does, the result stands and the response is disciplinary. If it does not, forfeiture can extend into situations where the match has, in fact, run its course. The resolution of that question will define the reach of regulatory intervention in cases of this kind.

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[For queries or feedback, the Author can be reached out at saksham.agrawal@nls.ac.in]

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PREFERRED CITATION: Saksham Agrawal, Play on after the final whistle? On the Senegal–CAF & Morocco dispute at CAS, Sports Law Review India, published on 1 May 2026.