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1 April 2026

CAF v Senegal: When A Walk Off Becomes A Forfeit And Football's Laws Walk Off The Field

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Football is built on the principle of finality. Once the referee blows the whistle, the result is meant to be settled. The AFCON 2025 final, however, defied that certainty.
Nigeria Antitrust/Competition Law
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Introduction

Football is built on the principle of finality. Once the referee blows the whistle, the result is meant to be settled. The AFCON 2025 final, however, defied that certainty. In a decision that stunned the football world, the Confederation of African Football overturned Senegal's on-field victory and awarded the title to Morocco based on forfeiture.

This unprecedented ruling raises profound legal questions about the meaning of "withdrawal" under Articles 82-84 of the AFCON Regulations, the authority of governing bodies to revisit matches concluded on the field, and the delicate balance between competition rules, the Laws of the Game, and Court of Arbitration for Sport (CAS) jurisprudence.

This article reviews the Laws of the Game, examining the concept of "withdrawal" during football matches, being the basis for the decision, and analysing the effect of the decision on African football.

CAF Announces Morocco Winner of AFCON 2025

2025 On March 17, 2026, the Confederation of African Football's (CAF) Appeal Board took an unprecedented step. It overturned the Africa Cup of Nations (AFCON) 2025 final and awarded Morocco a 3–0 victory, holding that Senegal forfeited the match by leaving the field during a late-game protest.2

The ruling rewrote the result of the January 18, 2026, final in Rabat, Morocco, a match Senegal had originally won 1–0 after extra time, courtesy of Pape Gueye's thunderous strike. The controversy stemmed from a VAR-assisted penalty awarded to Morocco against El Hadji Malick Diouf's challenge on Brahim Díaz, which triggered a 14 17 minute walk-off by Senegal's players before they returned; Díaz attempted a Panenka that Édouard Mendy easily saved, the tie then went into extra time3 and the eventual on-the-field success of the Senegalese team.

Regulations provisions, which was adopted by the Executive Committee of CAF on 12 April 2019 and came into force on the same date, that deem a team to have refused to play if it leaves the field without the referee's authorization and impose a 3–0 defeat for such an infringement. The official statement explicitly recorded the final as a 3–0 result in Morocco's favour. Senegal has now appealed the decision to CAS. 

Withdrawal Definitions under Article 82-84 of AFCON Regulations

Articles 82 – 84 of the AFCON Regulations provide as follows:

"Article 82: If, for any reason whatsoever, a team withdraws from the competition or does not report for a match, or refuses to play or leaves the ground before the regular end of the match without the authorisation of the referee, it shall be considered the loser and shall be eliminated for good from the current competition. The same shall apply to the teams previously disqualified by the decision of CAF.

Article 84: The team which contravenes the provisions of articles 82 and 83 shall be eliminated for good from the competition. This team will lose its match by 3-0 unless the opponent has scored a more advantageous result at the time when the match was interrupted; in this case, this score will be maintained. The Organising Committee may adopt further measures."

Articles 82-84 reproduced above appear uncompromising: leave the pitch and you forfeit. Yet their application to the AFCON final is less straightforward. From a cursory look at the Articles, the Articles appear to target leaving "before the regular end of the match," implying finality rather than a temporary disruption. Senegal's case is that it did not abandon the match; it returned, and the referee completed the game.4

This is not a semantic quibble. CAF's own chronology admits that the match resumed under the referee's authority and was completed to a sporting conclusion on the field. This was witnessed by spectators both on and off the pitch. If a strict reading of Article 82 equates any walk-off (no matter how brief or subsequently remedied) with withdrawal, the line between interruption and abandonment disappears. Notably, Article 83 uses a 15minute threshold for failure to appear at kickoff, but there is no defined time parameter for mid-match departures, leaving CAF to rely on discretion rather than a codified standard.5

The clash with IFAB's Law 5 IFAB's Law 5

(The Referee) is explicit: "The decisions of the referee regarding facts connected with play, including whether or not a goal is scored and the result of the match, are final." The law also reinforces that the referee's decisions and those of all match officials must be respected. In Rabat, Congolese referee Jean Jacques Ndala allowed play to continue after Senegal returned, and the match finished under his authority. CAF's retrospective forfeiture recharacterizes the incident as a withdrawal, effectively overruling the referee's management of the game months later.

From a governance perspective, this is a high-stakes collision: tournament regulations (CAF) versus the Laws of the Game (IFAB). The latter governs the global conduct and finality of match decisions, while the former governs competition administration. When the result has been produced on the field and ratified in real time by the referee, later administrative reversal sits uneasily with Law 5's finality principle.6 In our assessment, the IFAB rules ought to take precedence and override the CAF Regulations.

The field of play doctrine: CAS's long shadow

Beyond IFAB, the field-of-play doctrine deeply embedded in CAS jurisprudence counsels strict restraint in reviewing on-field decisions. CAS has consistently held that field of play decisions are final unless there is persuasive evidence of bad faith, malice, fraud, bias, arbitrariness, or corruption. The doctrine exists to protect officials' autonomy, preserve sporting finality, and avoid rewriting results in boardrooms.7

Recent summaries of CAS cases reiterate this narrow gateway. Even when a decision is later believed to be wrong, CAS intervenes only in extreme circumstances. The doctrine's rationale, sometimes called a "qualified immunity" for referees, has been affirmed by panels and commentary alike. Senegal's CAS appeal will almost certainly lean on this line of authority.8

Proportionality and precedent

The sanction in this case deserves scrutiny. Stripping a team of a trophy after full time is typically reserved for ineligibility, fraud or match-fixing categories involving integrity violations that undermine the competition's fairness at its core.9 Senegal's temporary departure from the field was followed by a return to play, the taking of the penalty, and the completion of the match under the referee's authority, which does not appear to strike at the core of the game.

The situation raises questions about how a brief interruption should be treated under the rules, and how the distinction between a temporary stoppage and full abandonment is determining appropriate sanctions.10

Historically, in the 2019 CAF Champions League final between Espérance de Tunis and Wydad Casablanca, the first leg ended 1–1, and in the second leg in Tunis, Espérance led 1–0 when Wydad appeared to score an equaliser, only for the referee to disallow it. When Wydad demanded a VAR review, it emerged that VAR was not functioning, prompting the Moroccan side to refuse to continue play and effectively abandon the match after a long delay, leading the referee to award Espérance the victory and the trophy on the night, but days later CAF controversially ordered a replay and asked for the trophy to be returned, a decision that was challenged at the Court of Arbitration for Sport (CAS), which annulled CAF's replay ruling on procedural grounds and sent the matter back to CAF's disciplinary bodies, who then ruled that Wydad had forfeited by abandoning the match and reinstated Espérance as champions, a verdict that was ultimately upheld when CAS rejected Wydad's final appeal, definitively confirming Espérance as the 2019 champions.

From the above, the absence of a clear temporal standard for mid-match departures compounds the uncertainty. Articles 82–84 provide no defined threshold for when a temporary walk-off becomes a forfeiture or refusal to play, leaving the determination to post hoc interpretation. CAF's application of these provisions in the present case effectively converts a brief interruption into a definitive forfeiture, thereby introducing a fluid and indeterminate standard.

The result is a precedent in which even matches completed under the referee's authority are no longer insulated from subsequent administrative reversal. This outcome sits uneasily with the field-of-play doctrine, which is intended to preserve finality by confining decisive authority to events on the pitch rather than retrospective determinations of it.11

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