CAS Case Digest · Verified against the full award text

CAS 2025/A/11678 — Al Zamalek Club v. Confederation of African Football

"Zamalek v. CAF" · CAS reduced Zamalek's USD 300,000 CAF fine to USD 75,000 for bringing football into disrepute during a Super Cup penalty incident.

What happened in Zamalek v. CAF

On 27 September 2024, Al Zamalek Club participated in the TotalEnergies CAF Super Cup 2024 against Al Ahly in Riyadh, Saudi Arabia. Following a VAR check and penalty award to Al Ahly between the 35th and 43rd minutes, Zamalek's players and officials surrounded the referee, caused a 5-to-7-minute stoppage of play, and gathered on or around the touchline. CAF's Disciplinary Board fined Zamalek USD 300,000 (USD 100,000 suspended) for improper conduct under Articles 82 and 83 of the CAF Disciplinary Code. The CAF Appeals Board upheld that decision on 4 August 2025. Zamalek appealed to CAS, arguing no violation occurred and, alternatively, that the fine was grossly disproportionate. The CAS Panel found that Zamalek had not been proven to have verbally threatened to abandon the match, but that its players' and officials' conduct nonetheless brought the game of football into disrepute under Article 83(1). However, the Panel held the USD 300,000 fine grossly disproportionate by reference to the Wydad Athletic Club precedent (USD 20,000 for actually abandoning a CAF Champions League Final), the fine's proximity to the regulatory maximum, and its relationship to the USD 500,000 winner's prize money. The fine was reduced to USD 75,000, of which USD 25,000 is suspended.

Procedural history of CAS 2025/A/11678

Following the 27 September 2024 CAF Super Cup match, CAF initiated disciplinary proceedings against Zamalek. On 24 October 2024, CAF's Disciplinary Board fined Zamalek USD 300,000 (USD 100,000 suspended) for improper conduct under Articles 82 and 83 of the CAF Disciplinary Code, and separately suspended and fined two individual players. Zamalek appealed to the CAF Appeals Board, which on 4 August 2025 dismissed the appeal and upheld the Disciplinary Board's decision in its entirety. On 14 August 2025, Zamalek filed a Statement of Appeal with CAS under Article R48 of the CAS Code, within the 10-day deadline prescribed by Article 48(3) of the CAF Statutes. The appeal concerned only the fine imposed on the club (items 4 and 5 of the Disciplinary Board's operative part), not the sanctions on individual players. A hearing was held by videoconference on 23 February 2026.

Key holdings in CAS 2025/A/11678

• Article 82 of the CAF Disciplinary Code, being general and vague, is unsuitable as an independent basis for a disciplinary sanction and must be read in connection with Article 83.
• The presumption of accuracy in Article 32 of the CAF Disciplinary Regulations does not extend to an official's own interpretation or presumption, and Zamalek established to the Panel's comfortable satisfaction that the General Coordinator's statement that players threatened to leave the match was inaccurate.
• A violation of Article 83(1) of the CAF Disciplinary Code requires that the game of football actually be brought into disrepute; potential or hypothetical disrepute is insufficient.
• Zamalek's conduct — surrounding the referee, causing a 5-to-7-minute stoppage of play at a globally broadcast flagship event — crossed the threshold of acceptable protest and constituted a violation of Article 83(1) read with Article 82.
• The USD 300,000 fine was grossly disproportionate in light of the Wydad Athletic Club comparator (USD 20,000 for actual match abandonment), the fine's proximity to the regulatory maximum, and its relationship to the USD 500,000 winner's prize money; a fine of USD 75,000 (USD 25,000 suspended) is proportionate.

How the CAS panel reasoned

The Panel first determined that Article 82 cannot stand alone as a disciplinary basis and that Article 83(1) is the operative provision. It applied the 'comfortable satisfaction' standard, consistent with CAS 2016/A/4831 and CAS 2011/A/2426, and confirmed that the burden of proof rests on CAF under Article 33(1) of the CAF Disciplinary Code. On the threat-to-withdraw allegation, the Panel reviewed video footage and found no visible signs of a threatened withdrawal; the General Coordinator's report was the sole source of that claim, unsupported by the Referee Report or Match Commissioner's Report, and the Match Commissioner had acknowledged in a televised interview that he did not understand Arabic. The Panel therefore held Zamalek had rebutted the Article 32 presumption. Nevertheless, the Panel found the broader conduct — surrounding the referee and causing a lengthy stoppage at a globally broadcast final — sufficient to bring the game into disrepute under the standard articulated in CAS 2008/A/1539 and CAS OG 16/009. On proportionality, the Panel used the Wydad Athletic Club case (USD 20,000 for actual abandonment, confirmed in CAS 2019/A/6483) as the primary comparator, noted the fine reached the regulatory maximum under Articles 87 and 91, and rejected CAF's argument that the USD 1,500,000 Riyadh Season payment should factor into the analysis. The Panel set a new fine of USD 75,000 (USD 25,000 suspended) as an effective deterrent that does not exceed what is reasonably required.

Why Zamalek v. CAF matters in CAS jurisprudence

This award clarifies that Article 82 of the CAF Disciplinary Code cannot serve as a standalone disciplinary basis and must be applied in conjunction with Article 83. It establishes that actual — not merely potential — disrepute must be proven to trigger Article 83(1), and that the 'comfortable satisfaction' standard governs CAF disciplinary proceedings. The award also uses the Wydad Athletic Club case as the benchmark for proportionality in CAF match-disruption sanctions, signalling that fines near the regulatory maximum are reserved for the most serious misconduct.

Cases cited in this award

CAS 2019/A/6483 CAS 2010/A/2090 CAS 2007/A/1426 CAS 2007/A/1396 & 1402 CAS 2020/A/6796 CAS 2016/A/4831

Frequently asked questions about Zamalek v. CAF

Did CAS find that Zamalek threatened to abandon the CAF Super Cup match?

No. The Panel reviewed video footage and found no clear indications that Zamalek's players or staff threatened to leave the match. The General Coordinator's report was the only source of that allegation, and it was unsupported by the Referee Report or the Match Commissioner's Report. The Panel held that Zamalek had established, to the comfortable satisfaction standard, that the threat-to-withdraw finding in the General Coordinator's report was inaccurate.

Why was Zamalek still found guilty even though the threat was not proven?

The Panel found that the sanction was not solely based on an alleged threat to withdraw but on the broader conduct of Zamalek's players and officials: surrounding the referee during the VAR check and causing a 5-to-7-minute stoppage of play at a globally broadcast flagship event. That conduct was held to exceed acceptable protest and to have brought the game of football into actual disrepute under Article 83(1) of the CAF Disciplinary Code, read with Article 82.

Why did CAS reduce the Zamalek fine from USD 300,000 to USD 75,000?

The Panel found the original fine grossly disproportionate on three grounds: (1) CAF had fined Wydad Athletic Club only USD 20,000 for actually abandoning a CAF Champions League Final in 2019, a more serious offence in a comparably high-profile match; (2) the USD 300,000 fine equalled the regulatory maximum under Articles 87 and 91 of the CAF Disciplinary Code, implying Zamalek's conduct was among the most serious possible, which the Panel rejected; and (3) the fine represented a substantial portion of the USD 500,000 winner's prize money. The Panel set USD 75,000 (USD 25,000 suspended) as proportionate.

What is the legal significance of the Wydad Athletic Club case for CAF disciplinary sanctions?

In CAS 2019/A/6483, CAS confirmed a USD 20,000 fine imposed by CAF on Wydad Athletic Club for actually abandoning the second leg of the 2019 CAF Champions League Final following a VAR dispute. In the Zamalek case, the Panel used this as the primary comparator for proportionality, noting that Zamalek's conduct was less serious (no actual abandonment) yet attracted a fine fifteen times larger. The Panel concluded that while the Wydad sanction level should be increased to reflect deterrence, USD 300,000 was still grossly disproportionate.

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.