Moctar Mahamoud Hamid v. Fédération Tchadienne de Football, Tahir Oloy Hassan

At a glance

Parties

Moctar Mahamoud Hamid (Chad) v. Fédération Tchadienne de Football Association (FTFA) and Tahir Oloy Hassan

Case no.

CAS 2025/A/11191

Forum and rules

Court of Arbitration for Sport, appeals arbitration procedure under the Code of Sports-related Arbitration (Articles R47 et seq.); proceedings in French

Treaty

Arbitration clause in Article 62(3) of the FTFA Statutes

Tribunal

Patrick Grandjean (Switzerland), Sole Arbitrator

Sector

Football; national federation governance and elections

Outcome

Appeal dismissed to the extent admissible (award of 30 October 2025). The rejection of the appellant's list of candidates for the FTFA Council was confirmed, and his challenges to the rival list and to the FTFA general assemblies were held inadmissible.

The dispute

Moctar Mahamoud Hamid headed one of two lists of candidates for the 2025 election of the Council of the Chadian football federation (FTFA). The list of the second respondent, Tahir Oloy Hassan, was the other. By decision N°001/FTFA/CED/2025 of 20 January 2025, the FTFA ethics and disciplinary commission accepted Oloy Hassan's list and rejected the appellant's. It cited inconsistent names and birth dates across documents and found that eleven candidates had not shown two years of continuous activity in football in the previous five years, as Article 32 of the FTFA Statutes requires. The FTFA appeals commission confirmed the rejection on 7 February 2025, and Oloy Hassan was elected President on 1 March 2025. Before CAS the appellant argued that the competent electoral appeals body had never been constituted, that the defects were minor and should have been open to correction as in 2023, that his right to be heard was violated, and that Oloy Hassan was ineligible because of his post at the national election agency (ANGE). He also sought annulment of the general assemblies of 14 December 2024 and 1 March 2025. The respondents argued that the process was regular and the defects serious, and that the appeal failed for lack of necessary joinder of the other list members.

Key holdings

1. CAS has jurisdiction under Article 62(3) of the FTFA Statutes. The appeal, filed on 24 February 2025 within the 21-day limit of Article R49 of the Code, is admissible insofar as it targets the rejection of the appellant's list. ¶¶ 61–68
2. The appellant bears the burden of proving the facts on which he relies. He did not prove that the electoral appeals commission was never constituted or that the procedure of Articles 8 and 9 of the Electoral Code was breached. His own exhibit, a cover letter of 7 February 2025 signed by the president of the electoral commission, suggested the contrary. ¶¶ 74–76, 79
3. Any breach of the right to be heard at FTFA level is cured by the full de novo review under Article R57 of the Code. In the alternative, if no internal appeal body existed, a direct appeal to CAS would equally have been timely. ¶¶ 77–78
4. The 2023 decision of the normalisation committee (CONOR) does not help the appellant. It was taken under time pressure at the end of its mandate, and it disqualified only one candidate per list. The chance to complete files was then provided for in the electoral calendar, but nothing similar appears in decision N°4/FTFA/SGI/2025 of 3 January 2025. ¶¶ 82–89
5. The two-year football-experience requirement (Articles 32 and 39(4) of the Statutes) is an essential eligibility criterion, not a formality. Eleven of the thirteen candidates on the appellant's list (more than 84%) did not meet it and never offered proof before the appeals commission or CAS. The remaining list of two could not satisfy the composition rules of Article 39, so the rejection is confirmed. ¶¶ 88–95
6. A candidate has standing only while his candidacy exists. Once it is validly rejected, he becomes a third party to the federation. His requests to set aside the validation of Oloy Hassan's list and the decisions of the general assemblies of 14 December 2024 (also out of time) and 1 March 2025 are therefore inadmissible for lack of legal interest. ¶¶ 97–102
7. The appeal is dismissed to the extent admissible and all other requests are rejected. The Sole Arbitrator did not need to decide the necessary-joinder objection or the ANGE incompatibility argument. The operative paragraphs on costs are redacted in the published award. ¶ 103; operative part

Procedural history

1. 20 November 2023The FIFA-appointed normalisation committee (CONOR) disqualifies Oloy Hassan's list in an earlier election process; its mandate ends on 30 November 2023 without a Council being elected.
2. 14 December 2024FTFA extraordinary general assembly elects the electoral, ethics and disciplinary, and appeals commissions.
3. 20 January 2025Ethics and disciplinary commission decision N°001/FTFA/CED/2025 accepts Oloy Hassan's list and rejects the appellant's; notified to the appellant on 1 February 2025.
4. 7 February 2025FTFA appeals commission decision n°001/FTFA/CR/2025 dismisses the appellant's internal appeal of 3 February 2025.
5. 24 February 2025Statement of appeal filed with CAS. A request for suspensive effect, filed on 16 February 2025, is rejected by order of 25 February 2025.
6. 1 March 2025Oloy Hassan is elected President of the FTFA Council by 58 votes out of 59.
7. 6 May 2025Patrick Grandjean is appointed Sole Arbitrator.
8. 18 July 2025Hearing held by video-conference.
9. 30 October 2025Award: appeal dismissed to the extent admissible.

Tribunal, counsel and experts

Decided by

• Patrick Grandjean Sole arbitrator, Court of Arbitration for Sport — appointed by the institution

For the claimant

Josué Ngadjadoum

For the respondent

Makarem Hajaji · Moustapha Kamara

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Keywords

• football governance
• federation elections
• eligibility requirements
• football experience requirement
• candidate list
• standing
• legal interest to act
• admissibility
• de novo review
• Article R57 CAS Code
• right to be heard
• burden of proof
• normalisation committee
• necessary joinder
• electoral appeals commission
• Chad
• FTFA Statutes

Summary generated with AI from the published documents — refer to the award for the authoritative text.