AFCON 2025 Final Dispute – A Field of Play Doctrine Analysis under CAF, FIFA, and CAS Jurisprudence

The dispute stemming from the AFCON 2025 final between Senegal and Morocco marks a pivotal moment inAfrican football law, not just as a contest for a championship but as a test of the limits between sportingindependence and legal oversight. After a completed match in which Senegal won, Morocco filed a casewith CAF’s Disciplinary Board, seeking, among other things, a declaration that they were the truechampions. While the CAF Disciplinary Board imposed sanctions without altering the result, the CAF Appeal Board has overturned the outcome and awarded the title to Morocco. Senegal’s appeal to the Court of Arbitration for Sport (CAS) thus brings the dispute into the realm of international sports law, where the key question is not just how CAF regulations are interpreted, but whether CAF’s appellateintervention breached the well-known Field of Play Doctrine established by CAS jurisprudence and part of FIFA’s regulatory structure.

The Field of Play Doctrine as the Cornerstone of Sports Law

The Field of Play Doctrine is one of the most enduring and defining principles in international sports law. Itrepresents the legal recognition that sport operates within a unique normative environment, one thatrequires finality, immediacy, and respect for on-field authority. At its core, the doctrine establishes that decisions made by referees and match officials during a sporting contest are final and not subject to external review, save in exceptional circumstances. The Doctrine stands as one of the most entrenched principles within Lex Sportiva, reflecting the fundamental proposition that sporting contests must be decided on the field by those entrusted with that authority, namely, referees and match officials, and not subsequently re- adjudicated by judicial or quasi-judicial bodies. This doctrine is not merelyprocedural; it is philosophical, grounded in the need to preserve the integrity, spontaneity, and finality of sport.

CAS has played a decisive role in crystallizing this principle into doctrine. Through a series of arbitral awards, CAS articulated the idea that “rules of the game” are distinct from “rules of law”, and that theformer are generally non-justiciable. CAS has consistently reinforced that decisions made during a match,even if later shown to be erroneous, are not subject to review unless they meet an exceptionally highthreshold

involving corruption, fraud, bad faith, or arbitrariness, supported by compelling evidence. The doctrine is further reinforced by the Laws of the Game, particularly Rule 5 of the International Football Association Board (IFAB), which vests referees with final authority over match decisions, including the result, therebyinsulating such decisions from external interference except in the most exceptional circumstances.

This insulation is not accidental; it is essential. Without it, every contentious match would become a potential legal dispute, undermining the certainty and immediacy that define sport. CAS jurisprudence has consistently and repeatedly cautioned against transforming arbitral panels into “second referees,” emphasizing that the role of legal bodies is not to re-officiate matches but to ensure that the regulatory framework is applied lawfully and fairly. In this respect, the Field of Play Doctrine functions as ajurisdictional boundary, delineating what is justiciable from what must remain within the exclusive competence of match officials.

Application of the Doctrine to the AFCON 2025 Final

When analyzing the facts of the AFCON 2025 final through the lens of the Field of Play Doctrine, the legal situation becomes much clearer. During the game, Senegalese players temporarily left the field in protest,but the referee did not stop the match or declare a forfeit; instead, he used his discretion to let the gamecontinue. Morocco, for its part, returned to play, took a penalty, and fully participated in the rest of the match, which ended with Senegal’s win. The referee’s decision to proceed with the game and accept itsresult was therefore a classic field-of-play decision, made within his authority and based on his real-time assessment of the situation.

According to established CAS jurisprudence, such a decision is presumed to be final and binding. It is crucial that there is no evidence indicating corruption, bad faith, or obvious arbitrariness. In fact, CAS has even ruled that admitted refereeing errors do not justify overturning results, emphasizing that sport accepts human imperfection as a natural part of competition. In this case, the referee’s actions cannot reasonably be regarded as arbitrary in the legal sense necessary to breach the Field of Play Doctrine.Instead, his decision to restart the match supports the principles of continuity, fairness, and the spirit ofthe game, which are fundamental to Lex Ludica.

CAF’s Regulatory Framework and Its Limits

CAF’s own regulatory instruments, when properly interpreted, reinforce rather than undermine the Fieldof Play Doctrine. For instance, Article 6 of the CAF Disciplinary Code affirms the finality of referees’ decisions, while Article 11 grants disciplinary bodies limited jurisdiction to address misconduct, includingincidents that may have escaped the attention of match officials. Importantly, this jurisdiction is confinedto disciplinary matters—such as sanctions, fines, and suspensions—and does not extend to altering thesporting outcome of a match. The Disciplinary Board’s initial decision adhered to this distinction by imposing sanctions without disturbing the result.

The CAF Appeal Board’s reliance on Articles 82, 83, and 84 of the AFCON Regulations, however, introduces significant legal difficulties. In our view, the drafting of these provisions is fraught with ambiguity,including the problematic use of the conjunction “and,” which leads to logical inconsistencies andtypographical errors that undermine the text’s credibility. More fundamentally, the Appeal Board’s interpretation effectively transforms a disciplinary provision into a mechanism for overturning a completed match, thereby conflating two distinct legal domains. This conflation is inconsistent with both CAF’sinternal framework and the broader principles of international sports law.

The Central Legal Error: Breach of the Field of Play Doctrine

In our view, the most significant flaw in the CAF Appeal Board’s decision lies in its failure to respect thejurisdictional boundary imposed by the Field of Play Doctrine. By overturning the match result, the Appeal Board effectively substituted its judgment for that of the referee, thereby encroaching upon a domain that is, by design, insulated from such review. This constitutes not merely an error of interpretation but a fundamental breach of the doctrinal architecture of sports law.

CAS has consistently resisted such encroachments, recognizing that the legitimacy of sport depends on theacceptance of results as they occur on the field. The doctrine serves as a safeguard against retrospectivejustice, which, while appealing in theory, is deeply destabilizing in practice. If sporting outcomes can berevisited and revised after the fact, the certainty and finality that underpin competitions are eroded, and the authority of match officials is diminished.

Equity, Conduct, and the Reinforcement of Finality

The parties’ conduct during the match further reinforces the application of the Field of Play Doctrine.Morocco’s decision to resume play, take the penalty, and participate in the remainder of the matchconstitutes a form of acquiescence that engages well- established equitable principles, including estoppelby conduct and approbation and reprobation. These principles operate to prevent a party from accepting a process when it is ongoing and subsequently challenging its validity when the outcome is unfavorable. Inthe context of sports law, such conduct strengthens the presumption of finality and militates against retrospective challenges.

Systemic Mischiefs Revealed

The dispute exposes several systemic mischiefs within the governance of African football, each of which ismagnified by the failure to adhere to the Field of Play Doctrine. First, the poor drafting of regulationsintroduces ambiguity that invites inconsistent interpretation and undermines legal certainty. Second, the CAF Appeal Board’s overreach reflects a misunderstanding of the limits of its jurisdiction; third, the absence of transparency, including the unavailability of reasoned decisions, erodes confidence in CAF’sjudicial processes.

Implications for CAS and the Likely Outcome

Given the centrality of the Field of Play Doctrine within CAS jurisprudence, it is highly probable that CASwill restore the original match result and reaffirm Senegal’s status as AFCON 2025 champions. Such adecision would not merely resolve the dispute but would serve as a reaffirmation of the doctrinalboundaries that govern international sport. CAS is likely to emphasize that disciplinary bodies may impose sanctions for misconduct but cannot, absent exceptional circumstances, alter the outcome of a match duly completed under a referee’s authority.

Lessons for National Sports Federations

For National Sports Federations, this dispute provides valuable lessons, especially about the Field of PlayDoctrine. First, there must be a clear and firm respect for the finality of on-field decisions, recognizing thatthe integrity of sport depends on referees’ authority and acceptance of their judgments. Second, regulatoryframeworks should be drafted with precision and clarity, ensuring that the scope of disciplinary powers is well-defined and does not interfere with sporting outcomes. Third, associations need to invest in governance structures that promote transparency, independence, and accountability within judicial bodies. Fourth, it is essential to implement real-time dispute resolution methods, such as CAS ad hoc divisions, to resolve issues quickly without the need for retrospective intervention. Lastly, national associations must align their practices with FIFA statutes and CAS jurisprudence, ensuring they operate within the broader framework of international sports law.

Final Thoughts

• The AFCON 2025 dispute ultimately highlights a core principle that goes beyond this specific case: the legitimacy of sport comes from what happens on the field, not from decisions made The Field of Play Doctrine is not just a technicality; it is the foundation that upholds the integrity ofsport. By deviating from this doctrine, the CAF Appeal Board has entered legally risky territory and set a dangerous precedent, which may have far-reaching implications for the finality of matchofficials’ (referees) on-field decisions.

• The expected intervention by CAS will likely restore doctrinal clarity, reaffirming that while law plays a vital role in sport, it must respect the boundaries that protect the sanctity of the game.

• In our considered view, the proper application of CAF regulations, FIFA principles, and CAS jurisprudence leads inexorably to the conclusion that the Field of Play Doctrine must Thelaw, properly understood, does not rewrite matches; it protects the conditions under which they are played.

Disclaimer:

This legal brief summarizes our reflections on the recent CAF Appeals Board decision regarding the AFCON2025 final match. It is not intended to serve as legal advice for any specific case you may be dealing with.For tailored legal guidance, please consult your preferred attorney or the undersigned.

Prepare by:

Prof. Saudin J. Mwakaje, Partner, NexLaw Advocates

Email: smwakaje@nexlaw.co.tz, info@nexlaw.co.tz

Tel. No: +25522213567, Cell: +255786 300132

Website: www.nexlaw.co.tz