The case involves Khaled Adenon, a professional football player from Benin, who appealed to the Court of Arbitration for Sport (CAS) against a FIFA decision imposing a 12-month global suspension and a CHF 10,000 fine for violent conduct toward a referee during a 2014 World Cup qualifying match. FIFA’s Disciplinary Commission initially sanctioned Adenon under Article 49 of its Disciplinary Code, and the Appeals Commission upheld the decision. Adenon then filed an appeal with CAS, challenging procedural fairness and requesting provisional suspension of the sanction. FIFA contested the admissibility of the appeal, but CAS allowed the proceedings to continue under its arbitration rules.
In its interim ruling, CAS addressed the request for provisional measures, emphasizing the need for concrete evidence of irreparable harm to justify suspending the sanction. Adenon argued that the suspension would damage his career, reputation, and mental health, as well as create financial pressure. However, CAS found his claims insufficiently substantiated, noting that mere exclusion from matches does not automatically warrant provisional relief. The ruling highlighted that professional athletes often face economic and psychological consequences from suspensions, and Adenon’s contractual stability—earning a monthly salary of €16,000 without penalty clauses—undermined his financial harm claims. FIFA countered that reputational damage stemmed from Adenon’s own actions, not the suspension, and dismissed his psychological harm claims as unproven.
The substitute president of the CAS Appeals Arbitration Chamber concluded that Adenon failed to demonstrate irreparable harm, a key requirement for granting provisional measures. Without meeting this threshold, the other conditions—likelihood of success on appeal and balance of interests—were not examined. The request for a suspensive effect was rejected, with costs deferred to the main proceedings. The decision reinforced CAS jurisprudence, which requires plausible evidence of irreparable harm to justify provisional relief, and underscored the high bar for such measures in sports arbitration. The case proceeded to a full hearing on the merits to determine the legality of FIFA’s disciplinary actions.