CAS Case Digest · Verified against the full award text

CAS 2025/A/11510 — Zamalek SC v. Confederation of African Football (CAF)

"Zamalek" · CAS halved Zamalek's USD 200,000 fine to USD 100,000 for security failures at the 2023/2024 CAF Confederation Cup final.

What happened in Zamalek

On 19 May 2024, Zamalek SC hosted RS Berkane in the second leg of the CAF Confederation Cup 2023/2024 final at Cairo Stadium. Following the final whistle, multiple security incidents occurred: supporters and club-affiliated individuals invaded the pitch, players carried and lit flares, the VVIP area became overcrowded, and senior officials including the CAF President and Egypt's Minister of Youth and Sports were obstructed from accessing the pitch for the medal ceremony. The CAF Disciplinary Board sanctioned Zamalek on 2 September 2024 with four home matches behind closed doors (two suspended for 12 months) and a USD 200,000 fine. The CAF Appeal Board dismissed Zamalek's appeal on 10 December 2024 (grounds notified 2 June 2025). Zamalek appealed to CAS, arguing strict liability should not apply or, alternatively, that the fine was grossly disproportionate. CAS upheld strict liability under Article 83.2 of the CAF Disciplinary Code but reduced the financial sanction by 50% to USD 100,000, citing CAF's own role in refusing Zamalek's security personnel in the VVIP area, the absence of physical harm or permanent stadium damage, and Zamalek's effectively clean disciplinary record over the preceding 15 years. The closed-doors sanction was not challenged and remains in full effect.

Procedural history of CAS 2025/A/11510

On 2 September 2024, the CAF Disciplinary Board issued the First Instance Decision imposing on Zamalek SC four home CAF interclub matches behind closed doors (two suspended for 12 months) and a fine of USD 200,000 for failure to maintain order and security during the CAF Confederation Cup 2023/2024 final second leg on 19 May 2024. Zamalek appealed to the CAF Appeal Board, which held a hearing on 18 November 2024 and dismissed the appeal, upholding the First Instance Decision in full. The grounds of the CAF Appeal Board's decision were notified to Zamalek on 2 June 2025. On 12 June 2025, Zamalek filed a Statement of Appeal with CAS under Articles R47 and R48 of the 2023 CAS Code, requesting annulment of all sanctions or, alternatively, reduction of the financial sanction to USD 5,000. A three-member panel was constituted and a videoconference hearing was held on 12 February 2026.

Key holdings in CAS 2025/A/11510

• Article 83.2 of the CAF Disciplinary Code establishes a strict liability regime imposing an obligation of result on the host club for order and security before, during, and after a match, irrespective of fault or negligence.
• Outsourcing security obligations to a third-party company does not relieve the host club of its own liability under the strict liability framework, as the club remains responsible for services rendered by companies it engages.
• The principle of strict liability is not unlimited and may yield to force majeure or, under certain conditions, conduct of third parties, but Zamalek invoked neither successfully.
• A financial sanction must comply with the principle of proportionality, and CAS will reassess it only where it is evidently and grossly disproportionate to the offence.
• A prior disciplinary sanction imposed approximately 15 years earlier carries limited weight and may be treated as a mitigating factor, effectively giving the club a clean record for proportionality purposes.

How the CAS panel reasoned

The Panel first confirmed that the CAF Disciplinary Code applied to the Match as a CAF-organised competition, and that Article 83.2 creates an obligation of result with no room for discretion: the mere occurrence of incidents triggers liability regardless of fault. The Panel rejected Zamalek's argument that outsourcing security to a private company could exculpate it, finding the club remained responsible for that company's performance. No force majeure was invoked. On proportionality, the Panel declined to annul the fine but found the USD 200,000 amount evidently disproportionate given: (1) CAF's own refusal on 19 May 2024 to allow Zamalek security personnel in the VVIP area, which influenced the disorder; (2) the absence of physical harm to persons or permanent damage to the stadium; (3) Zamalek's effectively clean record over the preceding 15 years; and (4) the fact that neither the CAF Disciplinary Board nor the CAF Appeal Board provided any per-breach breakdown of the fine. The Panel distinguished precedents cited by both parties on their facts. Applying a 50% reduction, it set the fine at USD 100,000, while leaving the four-match closed-doors sanction (not challenged by Zamalek) intact.

Why Zamalek matters in CAS jurisprudence

This award clarifies that Article 83.2 of the CAF Disciplinary Code imposes a true strict liability obligation of result on host clubs, with no fault-based escape route, but confirms that proportionality review remains available at CAS. The Panel's 50% reduction signals that CAF disciplinary bodies must provide per-breach reasoning for financial sanctions and that a governing body's own organisational decisions — here CAF's refusal to allow the host club's security personnel in the VVIP area — can constitute a mitigating factor even within a strict liability framework.

Cases cited in this award

TAS 2002/A/423 CAS 2012/A/2802 CAS 2014/A/3578 CAS 2018/A/6040 CAS 2016/A/4701 CAS 2013/A/3094

Frequently asked questions about Zamalek

Did CAS uphold the strict liability finding against Zamalek for the CAF Confederation Cup final incidents?

Yes. The Panel held that Article 83.2 of the CAF Disciplinary Code creates an obligation of result on the host club, meaning liability attaches upon the mere occurrence of incidents regardless of fault. Zamalek's argument that outsourcing security to a private company could exculpate it was rejected, as the club remained responsible for that company's performance.

Why did CAS reduce Zamalek's fine from USD 200,000 to USD 100,000?

The Panel applied the proportionality principle and found several mitigating factors: CAF's own refusal on 19 May 2024 to allow Zamalek security personnel in the VVIP area contributed to the disorder; no physical harm to persons or permanent stadium damage was reported; Zamalek had an effectively clean disciplinary record over the preceding 15 years; and neither the CAF Disciplinary Board nor the CAF Appeal Board provided any per-breach breakdown of the fine. A 50% reduction to USD 100,000 was deemed appropriate.

Was Zamalek's four-match behind-closed-doors sanction also reduced by CAS?

No. Zamalek did not challenge the closed-doors sanction before CAS, only the financial sanction. The Panel therefore made no determination on that part of the sanction, which remains in effect: four home CAF competition matches behind closed doors, with two matches suspended for a probationary period of 12 months.

What sanction did RS Berkane receive for its conduct at the same match?

Following Zamalek's production request, CAF disclosed that RS Berkane was subjected to a financial sanction of USD 45,000 in connection with the unsporting behaviour of its players and officials after the match. The Panel noted this to correct Zamalek's initial assertion that no sanction had been imposed on RS Berkane, while emphasising it was a separate matter from Zamalek's own liability.

Topics: Doping, ethics & governance at CAS

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