The Court of Arbitration for Sport (CAS) ruled on June 18, 2021, in a dispute between Ibrahim Wanglaouna Foullah and the Chadian Football Federation (FTFA) concerning the electoral process for the FTFA presidency. The case centered on Foullah's appeal against the FTFA's rejection of his candidacy and the subsequent election of Moctar Mahamoud Hamid as president. The CAS, with sole arbitrator Olivier Carrard, determined it lacked jurisdiction to hear the appeal, as the FTFA's statutes and electoral code did not provide for recourse to the CAS against decisions of the FTFA's Appeals Commission, rendering such decisions final under Article R47(2) of the CAS Code.
The dispute arose from the FTFA's electoral process in late 2020, which required candidates to meet specific eligibility criteria, including support from provincial leagues. Foullah's candidacy was declared inadmissible on November 3, 2020, due to insufficient support, while Hamid's was conditionally accepted. Foullah challenged this decision before the FTFA's Appeals Commission, which upheld the rejection, citing compliance with FTFA statutes. Foullah then appealed to the CAS, seeking annulment of the Appeals Commission's decision and alleging procedural irregularities, including unequal treatment and violations of FIFA guidelines. However, the CAS ruled it could not examine the merits of the case due to jurisdictional limitations.
The case also involved broader conflicts between the FTFA and the Chadian government, with the Ministry of Youth and Sports attempting to intervene in the electoral process. FIFA opposed this intervention, asserting the FTFA's autonomy, and the FTFA proceeded with the election on December 12, 2020, electing Hamid by acclamation. The government later challenged the election in court, and the FTFA suspended its activities in March 2021 following a withdrawal of authority by the Chadian government.
Throughout the proceedings, Foullah argued that the FTFA misinterpreted its statutes, unfairly rejected his candidacy, and conducted an undemocratic election. The FTFA maintained that its decisions were final and compliant with its statutes, emphasizing the specialized nature of sports law and the inappropriateness of external interference. The CAS's decision highlighted the autonomy of sports federations in resolving internal disputes and the limited scope for external judicial review. The case underscores the complexities of electoral governance in sports federations and the challenges of balancing autonomy with procedural fairness.
Ultimately, the CAS dismissed Foullah's appeal due to jurisdictional constraints, leaving the FTFA's decisions intact. The ruling reaffirmed the finality of internal appeals processes within sports federations and the importance of adhering to procedural rules when challenging electoral outcomes. The case serves as a notable example of the interplay between national governments, international sports bodies, and internal federation governance.