CAS Case Digest · Verified against the full award text

CAS 2024/A/10502 — Francis Adjetey v. Accra Hearts of Oak Sporting Club Limited & Ghana Football Association

"Adjetey" · CAS upheld a Ghanaian player's just-cause termination after his club failed to register him as a professional, awarding GHC 106,477.42 plus interest.

What happened in Adjetey

Francis Adjetey, a Ghanaian professional footballer, signed a four-and-a-half-year Professional Player Contract with Accra Hearts of Oak on 2 February 2023, earning GHC 2,000 per month. Despite the contract's explicit requirement that the Club register him as a professional, the Club registered him only as an amateur, excluded him from the 30-man squad, and failed to provide contractually guaranteed accommodation. After sending default notices on 31 August and 5 September 2023, Adjetey terminated the contract on 14 September 2023 — one day before the Ghanaian transfer window closed, making cure impossible. The GFA Players' Status Committee and Appeals Committee both declined jurisdiction, holding that the contract had not been deposited with the GFA as required by Article 29 of the GFA Premier League Regulations. CAS reversed, finding that Article 28 of the GFA RSTP grants the PSC jurisdiction over employment disputes without any registration precondition, and that allowing the Club to exploit its own failure to deposit the contract would violate equity and good faith. Exercising its de novo power under Article R57, CAS ruled on the merits, found just cause for termination, and ordered the Club to pay GHC 106,477.42 plus 5% interest per annum from 15 September 2023. The case matters because it firmly establishes that a club cannot weaponise its own administrative non-compliance to deny a player access to domestic dispute resolution.

Procedural history of CAS 2024/A/10502

On 8 October 2023, the Professional Footballers Association of Ghana filed a claim before the GFA Players' Status Committee (PSC) on Adjetey's behalf, alleging multiple contract breaches by Accra Hearts of Oak. On 1 December 2023, the PSC dismissed the claim for lack of jurisdiction, holding that the contract had not been deposited with the GFA as required by Article 29 of the GFA Premier League Regulations. On 11 December 2023, the PFAG appealed to the GFA Appeals Committee. On 26 February 2024, the Appeals Committee upheld the PSC's finding and confirmed its lack of jurisdiction. The Appealed Decision was notified to the parties on 26 March 2024. On 15 April 2024, Adjetey filed a Statement of Appeal with CAS under Articles R47 and R48 of the CAS Code, seeking both a ruling that the GFA had jurisdiction and, primarily, a de novo decision on the merits including compensation of GHC 106,477.42 plus 5% interest per annum from 15 September 2023.

Key holdings in CAS 2024/A/10502

• Article 28 of the GFA RSTP grants the PSC jurisdiction over employment disputes between players and clubs without imposing any contract-registration precondition, and Article 29 of the GFA PLR cannot be read to limit that access to justice.
• A club cannot invoke its own failure to deposit a contract under Article 29.3 of the GFA PLR to deny a player access to the GFA's internal dispute resolution mechanisms, as this would allow the club to benefit from its own non-compliance.
• A player's professional status under Article 2 of the GFA RSTP is determined by the substantive terms of the contract and the remuneration received, irrespective of the administrative designation used by the club in the registration system.
• The Club's failure to register the Player as a professional before the closure of the Ghanaian transfer window on 13 September 2023 rendered the 60-day cure period under Clause 8 of the Contract irrelevant and constituted a fundamental breach justifying just-cause termination under Clause 8 of the Contract and Article 14 of the FIFA RSTP.
• CAS exercised its de novo power under Article R57 of the Code to decide the merits directly, rather than remitting to the GFA, on grounds of procedural economy and the undue delay and burden a domestic restart would impose on the Appellant.

How the CAS panel reasoned

The Sole Arbitrator began by interpreting the relationship between the GFA RSTP and the GFA PLR. He found that Article 28 of the GFA RSTP, as the primary framework for employment disputes, confers jurisdiction on the PSC without any registration condition, while Article 29 of the GFA PLR addresses only administrative recognition of contracts and does not expressly restrict PSC jurisdiction. He rejected the Club's argument that Article 29.3 bars access to justice, noting that the deposit obligation falls primarily on the club ('shall'), whereas players are merely 'encouraged' to deposit. Allowing the Club to exploit its own breach of Clause 5.e of the Contract — which required it to register the Player — would violate equity and good faith. On professional status, the Arbitrator applied Article 2 of the GFA RSTP and the FIFA RSTP Commentary (Edition 2023), holding that substantive criteria (written contract, remuneration exceeding expenses) govern, not administrative labels; the T1 amateur registration form lacked the mutual intent required to amend the Contract. On just cause, the transfer window's closure on 13 September 2023 made cure impossible regardless of the 60-day notice clause. The Club's uncontested quantum of GHC 106,477.42 and the FIFA DRC's consistent practice of awarding 5% per annum interest (citing FIFA DRC decision REF. FPSD-14312 of 11 July 2024) supported the compensation award.

Why Adjetey matters in CAS jurisprudence

Adjetey establishes that a club's failure to deposit a player's contract with the national association cannot be weaponised to strip the player of access to domestic dispute resolution, reinforcing the principle that administrative non-compliance by the stronger party cannot defeat a player's right to justice. The award also reaffirms that professional status under Article 2 GFA/FIFA RSTP is determined by substantive contract terms, not administrative labels, and that CAS will exercise its de novo power rather than remit where domestic restart would cause undue delay.

Cases cited in this award

CAS 2020/A/7370

Frequently asked questions about Adjetey

Why did CAS find that the GFA had jurisdiction even though the contract was never deposited with the GFA?

The Sole Arbitrator held that Article 28 of the GFA RSTP grants the PSC jurisdiction over employment disputes without any registration precondition. Article 29 of the GFA PLR creates an administrative deposit requirement but does not expressly restrict PSC jurisdiction. Crucially, the deposit obligation fell primarily on the Club under Article 29.2, so allowing the Club to invoke its own non-compliance to deny the Player access to justice would violate equity and good faith.

Was Adjetey's termination valid even though he gave only 14 days' notice instead of the 60 days required by Clause 8 of the contract?

Yes. The Sole Arbitrator found that the Ghanaian transfer window closed on 13 September 2023 — the day before Adjetey terminated — making it impossible for the Club to register him as a professional regardless of how much time was given. Because the breach could not be cured within any notice period, the 60-day cure requirement under Clause 8 became irrelevant, and the termination on 14 September 2023 was with just cause under Clause 8 of the Contract and Article 14 of the FIFA RSTP.

How was the compensation of GHC 106,477.42 calculated in the Adjetey case?

The Player quantified his damages as the residual value of the Contract — the unpaid salary for the remaining term of the agreement — arriving at GHC 106,477.42. The Club did not contest this figure or raise any mitigating circumstances. The Sole Arbitrator found the amount consistent with Appendix A of the Contract and Article 16(1) of the GFA RSTP, and awarded it in full together with 5% interest per annum from 15 September 2023, in line with FIFA DRC practice as illustrated by FIFA DRC decision REF. FPSD-14312 of 11 July 2024.

Does signing an amateur registration form (T1) change a player's professional status under the GFA RSTP?

No. The Sole Arbitrator held that professional status under Article 2 of the GFA RSTP is determined by the substantive terms of the contract and the remuneration received, not by administrative designations. The T1 form is an administrative document, and its execution by Adjetey did not constitute a contractual amendment because there was no evidence of mutual intent by both parties to modify the Professional Player Contract. The FIFA RSTP Commentary (Edition 2023) on Article 2 further confirms that administrative categorisations cannot override the substantive professional-status criteria.

Topics: Art. 17 RSTP & contract termination at CAS

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