The case involves Adam Moukaîla Biyao, a football referee affiliated with the Togolese Football Federation (FTF), who faced disciplinary sanctions for alleged match-fixing during a first-division match between ANGES FC and ASKO FC on April 7, 2019. The match commissioner reported suspicions of corruption after ASKO FC won 1-0. Investigations revealed that referee Raouf Ouro-Bagna was approached by another referee, Aboza Kpanaké, to influence the match in favor of ANGES FC for a bribe, which Ouro-Bagna claimed to have refused. Ouro-Bagna also accused Biyao and assistant referee Kowou Gnamassou of accepting bribes. A recorded call between Ouro-Bagna and Kpanaké indicated the bribe money was returned after the "mission" failed. During hearings, Gnamassou initially admitted receiving money from Biyao but later retracted his statement, citing coercion. Biyao denied all allegations, demanding concrete evidence.
The FTF Disciplinary Commission imposed sanctions, including bans and fines, on Kpanaké, Biyao, Gnamassou, and Ouro-Bagna. Biyao and Kpanaké appealed to the FTF Appeals Commission, which reduced their bans, citing insufficient direct evidence. Ouro-Bagna’s sanctions were overturned as he had reported the corruption. Biyao later sought a review, claiming new evidence disproved Ouro-Bagna’s statements, but the Appeals Commission rejected this, ruling Ouro-Bagna’s testimony was not decisive in Biyao’s sanction.
Biyao then appealed to the Court of Arbitration for Sport (CAS) on January 3, 2020, arguing procedural unfairness and insufficient evidence. The CAS examined the case under FTF statutes and Togolese law, rejecting Biyao’s claims. The arbitrator found the Appeals Commission had properly heard Biyao’s arguments through his lawyer and that the sanction was based on corroborating evidence, including Biyao’s own admissions and Gnamassou’s statements. The CAS upheld the FTF’s decision, concluding the evidence supported the corruption allegations and Biyao’s procedural rights were respected.
The CAS’s final ruling on November 18, 2020, dismissed Biyao’s appeal and confirmed the FTF Appeals Commission’s decision, including the four-year ban and fine. The case underscores the challenges of proving corruption in football and the legal processes involved in disciplinary appeals, reaffirming the importance of internal dispute resolution mechanisms and the limited grounds for overturning decisions when procedural and evidentiary standards are met. The ruling emphasized the finality of the decision and dismissed any further claims.