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Home > AFCON 2025 > Not a Protest, but a Withdrawal: Why CAS is Likely to Uphold Morocco’s AFCON Title

Not a Protest, but a Withdrawal: Why CAS is Likely to Uphold Morocco’s AFCON Title

CAF’s overturning of the AFCON final’s result to crown Morocco champions was an override correction of an unprecedented breach of regulations. But this saga is far from over.

Samir BennisbySamir Bennis
Mar, 20, 2026
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Not a Protest, but a Withdrawal: Why CAS is Likely to Uphold Morocco’s AFCON Title

Image showing CAS as well as the AFCON cup. Creds: MWN

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Washington – On March 17, the ongoing controversy surrounding the results of the Africa Cup of Nations 2025 took a drastic turn in the host country’s favor. The CAF Appeals Committee declared Senegal the loser and Morocco the winner, reversing the title in what may go down as the most chaotic ending in AFCON history. The decision followed a wave of dissatisfaction from many Moroccans and sports analysts from Africa and around the world at CAF’s arbitrary ruling to award Senegal the title despite their unprecedented unsportsmanlike conduct.

When justice was served at the beginning of this week, Moroccans and Morocco supporters rejoiced in celebration. But the long battle is not over, as doubts have gradually begun to emerge as to whether the Court of Arbitration for Sport (CAS) will uphold or overturn that ruling.

These doubts have been further reinforced after several legal experts suggested that there is a significant likelihood that CAS may move toward annulling the CAF Appeals Committee’s decision and, consequently, restoring the title to Senegal.

One of the key arguments some of these experts are bringing to the table to support this hypothesis is that CAS may rule that the chaos that happened during the AFCON final is commonly referred to as “field-of-play matters.” These matters fall under the exclusive jurisdiction of the referee pursuant to Article 5 of the Laws of the Game. In other words, once the referee has officially brought the match to an end within regulation time, the result cannot be challenged even if the referee awarded a questionable penalty, disallowed a legitimate goal, or issued an unjustified red card.

Yet, the title may not be slipping back out of Morocco’s hands quite yet. A careful reading of CAF regulations, combined with the methodology that CAS consistently adopts in adjudicating similar disputes, leads to a different conclusion. Several decisive factors are likely to weigh in Morocco’s favor, demonstrating that the Senegalese team’s conduct does not fall within the realm of field-of-play decisions or disciplinary matters subject to interpretation or the referee’s discretion, but rather within the domain of competition regulations, which entail automatic sanctions triggered by clearly defined factual circumstances.

External interference in the course of the match

The first of these factors is that Senegal left the field of play mid-match, retreating to the locker room. Moreover, one of the Senegalese players, Ibrahim Mbaye, took advantage of his presence in the locker room to go live on TikTok, telling his followers that “the trophy was stolen from us.” This raises an obvious and fundamental question: how can Senegal plausibly argue that its conduct did not amount to a complete withdrawal from the match when one of the 11 players who had been on the pitch was simultaneously engaged in a live broadcast on social media?

In such circumstances, even if the Senegalese team subsequently returned to the field, their conduct can still be characterized as a complete withdrawal, particularly given its unprecedented nature. Never before has a team withdrawn to the locker room during a match, nor has a player paused active participation in play to livestream on social media.

The second major factor that strongly supports Morocco’s position is the intervention of external actors in the course of the match. The first instance concerns French football veteran Claude Le Roy, who entered the field of play without any legal capacity and spoke to player Sadio Mané, advising him to go to the dressing room and persuade his teammates to return. Le Roy later admitted that he warned Mané that failure to return to the pitch would expose the Senegalese team to severe sanctions.

The second instance involves communications that took place between the VIP tribune, the VAR room, and the referee. These are all facts that were acknowledged by Head of CAF’s Referees Committee Olivier Safari Kabene. More significantly, Kabene admitted that he had instructed the referee not to issue yellow cards to Senegalese players. These elements clearly demonstrate that external actors intervened in a manner that directly affected the course of the match.

Thirdly, Senegalese fans’ conduct in protest of the VAR-verified call to award Morocco a penalty is a further testament that the match was marred by external disturbances having nothing to do with field-of-play matters. Reports and social media footage documents fans acting out in protest in fits of violence and vandalism, threatening to storm the pitch. The disorderly conduct continued even to the moment when Brahim Díaz was taking the penalty kick.

All of these elements render reliance on Article 5 of the Laws of the Game untenable. That provision applies to technical decisions relating to the conduct of play, such as goals, penalties, and disciplinary sanctions, which fall within the referee’s discretionary authority.

By contrast, the present case concerns regulatory consequences that fall outside the referee’s discretion, including withdrawal from the field and the sanctions that follow. In such circumstances, the referee’s authority is neither absolute nor immune from review by CAF’s judicial bodies.

In Senegal’s withdrawal, the issue does not concern the application of the Laws of the Game,  over which the referee has exclusive authority, but instead competition regulations, which fall within the jurisdiction of CAF’s competent bodies.

A question of legality, more than principle

Regardless of the final score of the match, the central question the CAF Appeals Committee and, in all likelihood CAS – must examine is whether any conduct occurred during the match that violated CAF regulations.

Beyond the withdrawal itself, Senegal’s reliance on the independence and finality of the referee’s decisions is further undermined by the fact that the referee faced external pressure and was instructed not to apply the Laws of the Game strictly. Namely, Article 12, which requires that any player who leaves the field without authorization be shown a yellow card.

Accordingly, the assertion that the referee applied the Laws of the Game independently, and that the final result is therefore immune from review or challenge by CAF, cannot be sustained.

In the present case, it is abundantly clear that the Senegalese team completely withdrew from the field of play and deliberately employed this tactic as a means of exerting pressure, not only on the referee, but also on the concentration and competitive balance of the opposing team. This conclusion is reinforced by a clear video in which the Senegalese coach, Pape Thiao, openly acknowledges that he instructed his players to leave the match, further admitting that their withdrawal had a tangible impact on the Moroccan players’ focus and physical sharpness.

Such conduct cannot be reasonably characterized as a mere protest. Rather, it must be qualified, in legal terms, as a withdrawal. It is well established that players and technical staff may protest refereeing decisions while remaining on the field of play. This was not the case during the fateful AFCON final. What transpired went well beyond any notion of permissible protest: it constituted a coordinated withdrawal of the entire Senegalese team – including substitutes and technical staff – from the field, culminating in their retreat to the dressing room.

Accordingly, irrespective of the arguments Senegal may advance in an attempt to challenge the evidentiary basis relied upon by Morocco or the decision of the CAF Appeals Committee, these facts, taken together, unequivocally meet all the legal conditions required to establish a complete and unequivocal withdrawal, thereby triggering the automatic application of Articles 82 and 84 of CAF regulations. This is the case regardless of whether the referee subsequently allowed the match to resume.

The importance of interpreting rules to ensure effectiveness and avoid absurd outcomes

It may nevertheless be argued, as has been done by Raymond Hack, former chairman of the CAF Disciplinary Committee, that the CAF Appeals Committee misapplied Article 84 of its regulations. In remarks made to ESPN, Hack contended that Article 84 can only be properly invoked where both Articles 82 and 83 are violated cumulatively, rather than where only one of them is breached.

This argument rests on the premise that Article 84 provides for the exclusion of a team that violates the provisions of Articles 82 and 83 jointly, and does not explicitly extend to cases involving a breach of either provision individually. According to this reasoning, the absence of the disjunctive “or” in the wording of Article 84 allows Senegal to argue that, since it did not violate both provisions simultaneously, the article is inapplicable, thereby rendering the Appeals Committee’s decision legally flawed.

At first glance, this line of reasoning may appear persuasive and could suggest that Senegal has a viable legal avenue before CAS. However, its apparent strength dissolves upon closer scrutiny of both the structure of the relevant provisions and the interpretative principles consistently applied by CAS.

A fundamental tenet of CAS jurisprudence is that regulatory provisions must be interpreted in a manner that ensures their practical effectiveness, while avoiding interpretations that lead to illogical, contradictory, or unworkable outcomes. Under no circumstances can a rule be construed in a way that deprives it of any meaningful application.

Applied to the present case, this principle is decisive. It would be inherently illogical to interpret Articles 82 and 83 cumulatively, as such an interpretation would require the simultaneous occurrence of two mutually exclusive situations: on the one hand, a team withdrawing from the field of play during a match (Article 82), and on the other, the same team failing to show up for the match altogether (Article 83). By definition, these scenarios cannot happen at the same time.

It follows that the reference to Articles 82 and 83 in Article 84 concern distinct categories of violations, rather than imposing a cumulative condition. In other words, the occurrence of either scenario is sufficient, in and of itself, to trigger the sanction. Any alternative interpretation would render Article 84 devoid of practical effect and thus legally untenable.

In line with well-established principles of regulatory interpretation, whether applied by CAF’s judicial bodies or by CAS, the reference to Articles 82 and 83 must therefore be construed as encompassing alternative forms of misconduct, each independently capable of giving rise to the prescribed sanction. Any contrary reading would lead to an absurd and legally unacceptable outcome.

Accordingly, Raymond Hack’s argument, while superficially compelling, cannot withstand rigorous legal analysis and ultimately proves unpersuasive.

The risk of setting a dangerous precedent for the integrity of the game

Finally, and perhaps most importantly, Senegal’s conduct raises serious concerns regarding the integrity of the sport and the precedent that would be set were such behavior to go unsanctioned.

If accepted, Senegal’s position would effectively legitimize a practice whereby teams could interrupt matches, withdraw from the pitch, and exert pressure on match officials whenever they disagree with a refereeing decision. Such a precedent would fundamentally undermine the orderly conduct of competitions and erode the very foundations upon which football is built.

The purpose of CAF’s regulatory framework is to safeguard the integrity of its competitions, ensure equal opportunity, and uphold respect for both the Laws of the Game and the authority of referees. Likewise, CAS consistently seeks to interpret and apply these rules in a manner that preserves the credibility, stability, and sustainability of the sport, while discouraging any form of unsporting or coercive conduct.

In the present case, the conduct of the Senegalese team constitutes a clear departure from the principles of fair play and sporting integrity. To tolerate such behavior would not only reward non-compliance but would also risk normalizing conduct that could destabilize the game at its core.

For these reasons, there is a compelling likelihood that CAS will uphold the decision of the CAF Appeals Committee. Conversely, in the unlikely event that CAS were to overturn that decision, it would risk sending a troubling message to teams and players worldwide — that they can interrupt matches and exert pressure on referees without sanctions.

Given that CAS’s fundamental role is to uphold the integrity of sport and ensure respect for its governing rules, it is difficult to envisage a scenario in which it would legitimize conduct capable of undermining the very principles it is entrusted to protect.

Samir Bennis is the co-founder and publisher of Morocco World News. You can follow him on Twitter @SamirBennis.

Tags: afconCAFCASMoroccosenegal
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