CAS Case Digest · Verified against the full award text

CAS 2023/A/9822 — Kumasi King Faisal Football Club v. Ghana Football Association

"Kumasi King Faisal" · CAS dismissed King Faisal's appeal, holding that Isaac Mensah was not an unqualified player under GFA Premier League Regulations.

What happened in Kumasi King Faisal

Kumasi King Faisal Football Club finished 17th in the 2022/2023 Ghana Premier League with 42 points and a goal difference of minus 12, placing them in the relegation zone. On 6 May 2023, they lost 4-0 to Tamale City FC in match round 30. King Faisal protested, alleging that Tamale City FC fielded an unqualified player: the player listed as Isaac Mensah was also registered under the identity Jireh Kojo Nissi, constituting double registration under Articles 28 and 33 of the GFA Premier League Regulations. Both the GFA Disciplinary Committee and the GFA Appeals Committee dismissed the protest, finding that while double registration had occurred in the 2021/2022 Division One season, only Isaac Mensah was registered for the 2022/2023 Premier League season. King Faisal appealed to CAS seeking a 3-0 forfeit win and three points. The CAS panel confirmed the GFA Appeals Committee decision, finding that the Appellant failed to prove Isaac Mensah was not the player's true identity, and that in the 2022/2023 season the player held only one registration. The case matters because it clarifies that double-registration ineligibility under GFA rules is assessed season by season, and prior-season irregularities do not automatically carry over to disqualify a player in a subsequent season.

Procedural history of CAS 2023/A/9822

On 6 May 2023, Kumasi King Faisal filed a protest with the GFA Disciplinary Committee against Tamale City FC for fielding an unqualified player in match round 30. On 30 May 2023, the GFA Disciplinary Committee dismissed the protest, acknowledging that Isaac Mensah and Jireh Kojo Nissi were the same person but finding that Jireh Kojo Nissi was not registered with any club at the time of the match. King Faisal appealed to the GFA Appeals Committee, which on 14 June 2023 also dismissed the appeal, finding that double registration had occurred only in the 2021/2022 Division One season and not in the 2022/2023 Premier League season. The Appealed Decision was notified to the Appellant on 23 June 2023. On 11 July 2023, King Faisal filed a Statement of Appeal with CAS under Articles R47 and R48 of the CAS Code, seeking to set aside the GFA Appeals Committee decision, have Tamale City FC declared losers of the match, and be awarded 3 points and 3 goals. CAS jurisdiction was confirmed under Article 63(1) of the GFA Statutes (2019 edition) and Article 48 of the GFA Disciplinary Code (2019 edition).

Key holdings in CAS 2023/A/9822

• The burden of proving that a player is unqualified rests on the protesting club pursuant to Article 13 of the GFA Premier League Regulations.
• The available evidence was insufficient to establish that Isaac Mensah was not the true identity of the player, and the Appellant therefore failed to discharge its burden of proof on that issue.
• A player is not unqualified under Article 28(1)(d) of the GFA Premier League Regulations unless it is established that he was registered with more than one club in the relevant season; registration under two identities in a prior season does not suffice.
• Article 26(4)(c) of the GFA Premier League Regulations requires all players to be registered anew every season, meaning that a double registration from a previous season has no legal effect on a player's qualification status in a subsequent season.
• Because the player was not an unqualified player under the GFA Premier League Regulations, the claim that Tamale City FC should be declared losers of the match under Article 33 of the GFA Premier League Regulations could not be sustained.

How the CAS panel reasoned

The panel identified two distinct sub-issues: (1) whether Isaac Mensah was not the player's true identity, and (2) whether the player was in any event unqualified due to double registration. On identity, the panel noted that Isaac Mensah was registered in the FIFA Connect System with birth date 20 June 1998 and Jireh Kojo Nissi with birth date 21 June 2003, suggesting Isaac Mensah had been registered longer. A video in which the player stated his name was Jireh Kojo Nissi was filed, but the panel found this insufficient, noting the absence of ID documents, certificates, or witness testimony. Applying Article 13 of the GFA Premier League Regulations, the panel held the Appellant had not discharged its burden of proof on identity. On double registration, the panel found it established that both names were registered for the 2021/2022 Division One season, but only Isaac Mensah was registered for the 2022/2023 Premier League season. Relying on Article 26(4)(c), which mandates fresh registration each season, the panel held that prior-season double registration had no carry-over effect. Even on a broader reading of Article 28(1)(d) covering same-club dual-identity registration, the player held only one identity in the 2022/2023 season. The panel expressly declined to address consequences had the player been found unqualified, and noted that 2021/2022 season allegations fell outside the scope of the appeal.

Why Kumasi King Faisal matters in CAS jurisprudence

This award establishes that under GFA Premier League Regulations, player eligibility for double-registration purposes is assessed strictly on a season-by-season basis, given the mandatory annual re-registration rule in Article 26(4)(c). A club cannot obtain a match forfeiture based on an opponent's double registration in a prior season if only one identity was registered in the season at issue. The case also reaffirms that the protesting club bears the burden of proving ineligibility, and that video evidence alone, without corroborating identity documents or witness testimony, is insufficient to establish a player's true identity.

Frequently asked questions about Kumasi King Faisal

Did CAS rule that Tamale City FC's player was qualified despite having two registered identities in the FIFA Connect System?

Yes. The CAS panel in Kumasi King Faisal v. GFA held that because only Isaac Mensah was registered for the 2022/2023 Ghana Premier League season, the player held a single valid registration for that season. The double registration under the name Jireh Kojo Nissi had occurred only in the 2021/2022 Division One season, and Article 26(4)(c) of the GFA Premier League Regulations requires all players to be registered anew every season, extinguishing any carry-over effect.

What evidence did Kumasi King Faisal submit to prove the player's true identity was Jireh Kojo Nissi, and why did CAS reject it?

King Faisal submitted a video in which the player stated his name was Jireh Kojo Nissi, and a letter from Super Rainbow FC dated 23 May 2023 denying any involvement in registering Jireh Kojo Nissi. The panel found this insufficient because no ID documents, birth certificates, or witness testimony were presented, and noted that Isaac Mensah's FIFA Connect System registration dated to birth date 20 June 1998 while Jireh Kojo Nissi's showed 21 June 2003, suggesting Isaac Mensah had been registered longer. The Appellant therefore failed to discharge its burden of proof under Article 13 of the GFA Premier League Regulations.

What are the consequences under GFA Premier League Regulations if a team is found to have fielded an unqualified player?

Under Article 33(1)(e) and Article 33(2) of the GFA Premier League Regulations, the offending team is considered to have lost the match and the innocent team is awarded three points and three goals, unless the innocent team was already leading by more than three goals. Additionally, under Article 33(5), the defaulting club loses three points from its accumulated points, is fined GH¢5,000.00 (50% payable to the opposing club), and must pay the opposing club's transportation expenses if playing at home.

How did Kumasi King Faisal's relegation relate to the protest, and did winning the case at CAS level matter for their league position?

King Faisal finished 17th in the 2022/2023 Ghana Premier League with 42 points and a goal difference of minus 12, placing them in the relegation zone. They sought to have the 4-0 loss to Tamale City FC on 6 May 2023 converted into a 3-0 forfeit win, which would have awarded them three points and three goals. CAS dismissed the appeal and confirmed the GFA Appeals Committee decision, meaning the match result stood and King Faisal's relegation was not affected by the proceedings.

Topics: Doping, ethics & governance at CAS

Source: official award. This digest was generated by LexXi from the full award text and machine-verified against it — every figure, article and citation above appears in the source. It is an editorial summary, not legal advice. See how ElevenLex verification works.