CAS Case Digest · Verified against the full award text

CAS 2025/A/11904 — Asaria SC v Libyan Football Federation (LFF) & Wefaq Ejdabya & Al-Dhara SC & Al-Khoms FC

"Asaria" · CAS dismissed as inadmissible Asaria's appeal seeking reinstatement in the Libyan Premier League after the 2025/2026 season had already commenced.

Award date	11 August 2026
Panel	Sole Arbitrator: Mr Patrick Grandjean, Attorney-at-law, Belmont-sur-Lausanne, Switzerland
Outcome	Appeal dismissed as inadmissible; Asaria SC bears the costs of the arbitration (exact cost figures redacted in the published text); all other motions dismissed.
Provisions	Art. R47 CAS Code Art. R49 CAS Code Art. R50 CAS Code Art. R55 CAS Code Art. R56 CAS Code Art. R57 CAS Code Art. R58 CAS Code Art. R64 CAS Code Art. R44.2(8) CAS Code Art. 67(1) LFF Statutes Art. 23(2) LFF Statutes Art. 39 LFF Statutes Art. 59 Swiss Civil Procedure Code (CPC) Art. 125 lit. a Swiss CPC Art. 182 Swiss Private International Law Act (PILA) Art. 190(2)(c) Swiss PILA (LDIP) Art. 29(2) Swiss Federal Constitution Art. 5 FIFA Regulations on the Status and Transfer of Players Art. 6 FIFA Regulations on the Status and Transfer of Players Art. 21 FIFA Disciplinary Code

What happened in Asaria

Asaria SC, a Libyan football club, was relegated from the LFF Premier League at the end of the 2024/2025 season after finishing last in Group D with 12 points. Al-Khoms FC had fielded several players registered in breach of a FIFA registration ban in force since 5 November 2024. On 11 October 2025, the LFF Board of Directors issued Decision No. 155/2025, reinstating Al-Dhara SC and Wefaq Ejdabya in the 2025/2026 Premier League on the basis of registration violations that had distorted competition results, but did not mention Asaria. Asaria appealed to CAS on 30 October 2025, arguing unequal treatment and seeking its own reinstatement. It also sought provisional measures, which were dismissed on 1 December 2025. The 2025/2026 season began on 11 December 2025. The Sole Arbitrator held the appeal inadmissible on three cumulative grounds: (1) annulling the Appealed Decision would not automatically reinstate Asaria; (2) Asaria's situation was not comparable to Al-Dhara's or Wefaq's because it had remained entirely passive and never raised complaints before the LFF; and (3) by the time of the award the season had substantially progressed, rendering reinstatement practically impossible and the appeal moot. The case illustrates that a club's failure to exhaust internal protest mechanisms and its procedural passivity can defeat a later equal-treatment claim before CAS.

Procedural history of CAS 2025/A/11904

During the 2024/2025 LFF Premier League group stage, Al-Khoms fielded players registered in breach of a FIFA ban. Asaria lost to Al-Khoms on 6 January 2025 (0–2) and on 27 February 2025 (initially won 3–1 but was then given a 2–0 forfeit defeat after Al-Khoms' protest). Asaria never lodged a protest regarding Al-Khoms' use of ineligible players. Al-Dhara, by contrast, filed a timely protest regarding the 11 April 2025 match, exhausted internal remedies, and appealed to CAS (CAS 2025/A/11619). On 11 October 2025, the LFF Board of Directors issued Decision No. 155/2025 reinstating Al-Dhara and Wefaq in the 2025/2026 Premier League but not Asaria. Asaria filed its Statement of Appeal with CAS on 30 October 2025 and simultaneously requested provisional measures. The Deputy President of the CAS Appeals Arbitration Division dismissed the provisional measures on 1 December 2025. The LFF filed its Answer on 8 January 2026 and Al-Dhara on 13 January 2026. The Sole Arbitrator decided against bifurcation and against holding a hearing, resolving the matter on written submissions alone.

Key holdings in CAS 2025/A/11904

The LFF Board of Directors' Decision No. 155/2025 constitutes an appealable 'decision' within the meaning of Article R47 of the CAS Code and Article 67(1) of the LFF Statutes, as it is a unilateral act intended to produce legal effects on identifiable members.
CAS has jurisdiction over appeals against decisions of a federation's executive body where no provision clearly and unequivocally limits the right of appeal solely to decisions of judicial bodies.
Annulment of the Appealed Decision would not automatically reinstate Asaria, since the decision neither addressed Asaria's situation nor modified its standings; Asaria therefore has no interest in its annulment.
A club that remained entirely passive and never raised complaints before the federation cannot rely on unequal treatment compared to clubs that actively pursued internal remedies, because their situations are not comparable.
Once the LFF 2025/2026 Premier League had substantially progressed following dismissal of provisional measures, Asaria's interest in reinstatement ceased to exist and the appeal became moot.

How the CAS panel reasoned

The Sole Arbitrator first confirmed jurisdiction, finding that the Appealed Decision was a binding unilateral act producing legal effects and that no LFF provision explicitly excluded appeals against Board decisions. He then addressed admissibility in three steps. First, he found that mere annulment of the Appealed Decision would only remove benefits granted to Wefaq and Al-Dhara without conferring any advantage on Asaria, since the decision did not address Asaria's standing or results. Second, he rejected the unequal-treatment argument by distinguishing Asaria's situation from that of Al-Dhara, which had filed a timely protest, exhausted internal remedies, and seized CAS (CAS 2025/A/11619), and from Wefaq, whose reinstatement was linked to prior complaints and FIFA recommendations. Asaria, by contrast, played two matches against Al-Khoms without ever raising the ineligible-player issue and brought no complaint before the LFF prior to the Appealed Decision. The LFF Board therefore had no reason to consider Asaria's situation. Third, applying Swiss law (Article 59 CPC) as lex arbitri, the Sole Arbitrator held that Asaria's interest in reinstatement had become moot because the 2025/2026 season had already substantially progressed after the provisional measures were dismissed on 1 December 2025, and Asaria itself had acknowledged that a lost season cannot be reconstructed. No financial compensation claim had been raised or evidenced.

Why Asaria matters in CAS jurisprudence

This award clarifies that a club's complete procedural passivity during a season — failing to protest matches involving ineligible opponents — precludes a later equal-treatment claim before CAS when a federation's corrective decision benefits only those clubs that actively pursued internal remedies. It also confirms that CAS appeals become moot once the season has substantially progressed and provisional measures have been denied, reinforcing the critical importance of seeking and obtaining interim relief promptly. The case further establishes that executive-body decisions of a national federation are appealable to CAS absent an explicit regulatory exclusion.

Decision: Appeal dismissed as inadmissible; Asaria SC bears the costs of the arbitration (exact cost figures redacted in the published text); all other motions dismissed.

Cases cited in this award

CAS 2025/A/11619 CAS 2019/A/6294 CAS 2017/A/5186 CAS 2024/A/11019 CAS 2022/A/9277 CAS 2015/A/4213

Frequently asked questions about Asaria

Why did CAS dismiss Asaria's appeal even though Al-Khoms fielded ineligible players in matches against Asaria?

The Sole Arbitrator found that Asaria had remained entirely passive: it never lodged a protest after either the 6 January 2025 or 27 February 2025 matches against Al-Khoms, and it raised no complaint before the LFF prior to the Appealed Decision. Because Asaria's situation was therefore not comparable to Al-Dhara's (which had filed a timely protest and exhausted all internal remedies) or Wefaq's (whose reinstatement followed prior complaints and FIFA recommendations), the equal-treatment argument failed. The LFF Board of Directors had no reason to consider Asaria's situation when it issued Decision No. 155/2025.

Did the Asaria case establish that CAS can hear appeals against decisions of a federation's board of directors?

Yes. The Sole Arbitrator held that the LFF Board of Directors' Decision No. 155/2025 was an appealable decision under Article R47 of the CAS Code and Article 67(1) of the LFF Statutes because it was a unilateral act intended to produce legal effects on identifiable members. He further held that, in the absence of a provision clearly and unequivocally limiting appeals to decisions of judicial bodies only, decisions of executive bodies are not excluded from CAS review.

Why did Asaria's appeal become moot in the Asaria v LFF case?

Asaria's sole objective was reinstatement in the LFF 2025/2026 Premier League. Its request for provisional measures was dismissed on 1 December 2025, and the season began on 11 December 2025. By the time the evidentiary proceedings closed, more than four months of the season had elapsed. Applying Swiss law (Article 59 CPC) as lex arbitri, the Sole Arbitrator held that a club cannot be reinstated at such an advanced stage of a championship, and Asaria itself had acknowledged that lost matches and opportunities cannot be reconstructed retrospectively. No financial compensation claim had been raised or evidenced, so the appeal was declared moot.

What lesson does the Asaria case offer clubs that discover opponents fielded ineligible players during a season?

The award strongly signals that clubs must act promptly through the prescribed internal protest mechanisms — in the LFF context, a written protest within 48 hours of the match — and must exhaust all internal remedies before approaching CAS. Asaria played two matches against Al-Khoms involving ineligible players without ever raising the issue, which meant it could not later invoke equal treatment when the LFF issued a corrective decision benefiting only those clubs that had actively pursued their claims. Procedural passivity will not be cured by a subsequent federation governance decision.

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