Pyramids FC v. Egyptian Football Association (EFA), Egyptian Professional Clubs League, Al Ahly SC & Zamalek Sporting Club
CAS 2025/A/11443 Pyramids FC v. Egyptian Football Association (EFA), Egyptian Professional Clubs League, Al Ahly SC & Zamalek Sporting Club
ARBITRAL AWARD delivered by the
COURT OF ARBITRATION FOR SPORT
sitting in the following composition:
President: Mr Frans M. de Weger, Attorney-at-Law in Haarlem, The Netherlands Arbitrators: Prof. Dr. Christoph Müller, Professor in Neuchâtel, Switzerland Ms Laila El Shentenawi, Attorney-at-Law in Dubai, United Arab Emirates
in the arbitration between
Pyramids FC, Egypt Represented by Mr Dario Marzorati and Mr Lukas Rusch, Attorneys-at-Law in Zurich, Switzerland
- Appellant –
and
Egyptian Football Association (EFA), Egypt - First Respondent –
and
Egyptian Professional Clubs League, Egypt Represented by Mr Abdallah El Shehaby, Attorney-at-Law in Cairo, Egypt - Second Respondent –
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and
Al Ahly SC, Egypt Represented by Mr Daniel Magdi Louis, Attorney-at-Law in Dubai, United Arab Emirates - Third Respondent –
and
Zamalek Sporting Club, Egypt Represented by Dr Kamal Shoaib, Legal Consultant in Cairo, Egypt - Fourth Respondent –
*****
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I. PARTIES
1. Pyramids FC (the “Appellant” or “Pyramids”) is an Egyptian football club affiliated to the Egyptian Football Association (EFA), with its registered office in Cairo, Egypt.
2. The Egyptian Football Association (the “First Respondent” or “EFA”) is the national governing body of football in Egypt, with its registered office in Cairo, Egypt.
3. The Egyptian Professional Clubs League (the “Second Respondent” or “EPL”) is the governing body of the Egyptian Premier League (the “Nile League”), with its registered office in Giza, Egypt.
4. Al Ahly SC (the “Third Respondent” or “Al Ahly”) is an Egyptian football club affiliated to EFA, with its registered office in Cairo, Egypt.
5. Zamalek Sporting Club (the “Fourth Respondent” or “Zamalek”) is an Egyptian football club affiliated to EFA, with its registered office in Cairo, Egypt.
6. The First, Second, Third and Fourth Respondent are hereinafter jointly referred to as the “Respondents”.
7. The Appellant and the Respondents are hereinafter jointly referred to as the “Parties”.
II. INTRODUCTION
8. The present appeal arbitration proceedings concern an appeal lodged by the Appellant against a decision issued by the EFA Appeal Committee dated 15 May 2025 (the “Appealed Decision”).
9. In the Appealed Decision, the EFA Appeal Committee determined that the appeal filed by the Appellant against a decision of the EPL’s Board of Directors dated 30 March 2025 was inadmissible, on the ground that such decision was final and binding and therefore fell outside the EFA Appeal Committee’s jurisdiction.
10. In these proceedings, the Appellant is challenging the Appealed Decision and requests the Court of Arbitration for Sport (the “CAS”) to declare that the Appealed Decision is set aside. The Appellant’s position is supported by the Fourth Respondent, whereas the First Respondent takes a neutral stance and the Second and Third Respondent seek confirmation of the Appealed Decision.
III. FACTUAL BACKGROUND
11. Below is a summary of the main relevant facts, as established on the basis of the submissions of the Parties and the evidence examined in the course of the proceedings. This background information is given for the sole purpose of providing a synopsis of the matter in dispute. Additional facts may be set out, where relevant, in connection with the legal discussion.
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A. Background Facts
12. On 5 March 2025, the first phase of the 2024/2025 Nile League season concluded, thereby determining the composition of the Championship and Relegation Groups.
13. On 6 March 2025, EPL announced the fixtures for the first round of the Championship Group final stage of the Nile League. Among these fixtures was the match between Zamalek and Al Ahly, scheduled to be played on 11 March 2025.
14. On 9 March 2025, Al Ahly submitted a formal request to EPL, seeking the appointment of foreign referees for its match against Zamalek.
15. Following Al Ahly’s request, also on 9 March 2025, EPL referred the matter to the EFA Referee Committee:
“Greetings,
We extend to Your Excellency and the esteemed members of the EFA Board our warmest regards and sincere wishes for continued success.
As part of the ongoing coordination and cooperation between the EPL and the EFA, and in our mutual efforts to ensure fair competition among clubs, we respectfully submit to you a formal request to appoint three foreign refereeing crews for the following matches: 1 – Zamalek vs. Al Ahly, scheduled to be held on Tuesday, March 11, 2025, at Cairo International Stadium at 9:30 PM. 2 – Pyramids FC vs. Al Ahly, scheduled for Saturday, April 11, 2025, at 30 June Stadium at 7:00 PM. 3 – Zamalek vs. Pyramids FC, scheduled for Tuesday, May 13, 2025, at Cairo International Stadium at 7:00 PM.
The EPL will bear all expenses related to the foreign referees, reflecting our dedication to transparency and fairness in the competition for the Nile League Championship, and to support the efforts of the new foreign expert in restructuring and developing the refereeing system. With utmost respect and appreciation,”
16. On 10 March 2025, Al Ahly sent a letter to EFA, reiterating its request for foreign referees to be appointed for the match scheduled on 11 March 2025, with reference to EPL’s correspondence dated 9 March 2025 on the same matter.
17. On that same date, the EFA’s Referee Committee appointed an Egyptian refereeing crew for the match of Al Ahly against Zamalek on 11 March 2025.
18. On 11 March 2025, in the morning, Al Ahly sent an official statement to EPL, which reads as follows:
“Greetings,
I am pleased to extend to you the regards of the President of Al Ahly Club’s Board of Directors, along with my personal greetings.
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With reference to the upcoming match between the first football team of Al Ahly and Zamalek in the first round of the final stage of the Egyptian Premier League for the 2024/2025 season, scheduled to take place on Tuesday, March 11, 2025, we would like to inform you that Al Ahly’s Board of Directors, in its emergency meeting held on Tuesday, March 11, 2025, decided to adhere to the decision of the EPL to hold the aforementioned match with a foreign refereeing team.
In the event that foreign referees are not appointed, Al Ahly Club has decided not to continue in the league.
Kindly take note of the above.”
19. On the same date, later that day, Al Ahly did not appear for the scheduled match against Zamalek. Consequently, the match was not played.
20. On 15 March 2025, Al Ahly announced that it had filed a complaint with the Egyptian Olympic Committee (“EOC”), alleging regulatory breaches by EPL and EFA in relation to the organization and administration of the final stage of the 2024/2025 Nile League.
21. On the same date, EPL’s Competition Department issued a disciplinary decision against Al Ahly, finding the club in breach of the Competition Regulations due to its withdrawal from the match against Zamalek (“EPL’s First Decision”). EPL’s First Decision provided as follows:
“1 – Certification of the result of the match considering Zamalek SC the winner by a score of 3-0 in accordance with Article 17.4 of the Competitions Regulations.
2 – Deduction of three points from Al Ahly SC in addition to the points for the match in which it was deemed defeated in addition to bearing all losses resulting the loss of income from commercial contracts, broadcasting contracts, and all other expenses incurred from participating in the competition matches before the withdrawal, based on the request issued by the rights holders. In accordance with article 17.8 of the Competition Regulations.
3 – The Egyptian Professional Clubs League is awaiting a decision on the complaint submitted by Al Ahly SC to the Egyptian Olympic Committee and will abide by the Olympic Committee’s decision in this regard.”
22. On 16 March 2025, Al Ahly filed a second complaint with the EOC against EPL’s First Decision, requesting to combine the two complaints and that the EOC annul all decisions issued by EFA and EPL against Al Ahly.
23. On 24 March 2025, Al Ahly filed an appeal before the EFA Appeal Committee against EPL’s First Decision, requesting that the match be replayed under the supervision of a foreign refereeing crew.
24. On 25 March 2025, EOC issued its decision, dismissing Al Ahly’s complaints dated 15 and 16 March 2025, holding that the procedures undertaken by EPL were valid
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and compatible with the Competition Regulations governing the 2024/2025 Nile League season.
25. On 30 March 2025, Al Ahly sent a memorandum to EPL, outlining ten points addressing alleged organizational and procedural shortcomings committed by EPL and EFA, and requesting EPL to reconsider EPL’s First Decision.
26. On the same date, later that day, EPL’s Board of Directors reviewed the matter and issued a new decision (“EPL’s Second Decision”). While maintaining the 3-0 victory in favour of Zamalek and upholding the financial penalties imposed on Al Ahly, EPL’s Board of Directors decided not to deduct three points from Al Ahly, invoking Article 63.2 of the Competition Regulations. EPL’s Second Decision reads as follows:
“Reference is made to Al Ahly’s complaint regarding the events of the Zamalek and Al Ahly match in the first round of the final stage. In accordance with the League’s Board of Directors powers granted by article 63/2 of the Nile League Competition Regulations for 2024/2025 season. Given that the league regulations were held exceptionally, the short period between the issuance of the schedule of the final stage and the first stage to determine the teams competing in each group, the holding of the Egypt Cup Matches, in addition to the international break during the month of March and the League’s commitment to ending the league competition by the end of May, which necessitates holding at least one round during the period from March 11th to the 13th of 2025, which led to holding the first round only five days after the end of the final stage. Consequently, the league and Al Ahly’s request to bring in foreign referees, a legitimate right guaranteed to all clubs by the regulations, were not met. Furthermore, based on the contents of its complaint, Al Ahly SC did not aim to provoke a crisis or withdraw from the summit match, but rather sought to seek greater justice for all parties. After studying the documents included in the complaint, the League’s Board of Directors decided that the Competitions Committee’s sanctions in its decision No. 50 issued on 15/03/2025 shall be as follows:
1- Approving the match result by considering Zamalek SC the winner with a score of 3-0 in accordance with Article 4.17 (sec.) of the Competition Regulations. 2- Bearing the financial fines in accordance with Article 17.8 (sec.) of the Competition Regulations.”
B. Proceedings before the EFA Appeal Committee
27. On 2 April 2025, Pyramids and Zamalek filed an appeal with the EFA Appeal Committee challenging EPL’s Second Decision.
28. On 10 April 2025, Al Ahly also filed an appeal with the EFA Appeal Committee, by way of amendment to its original appeal dated 24 March 2025. Through this amended appeal, Al Ahly contested the sanctions under EPL’s Second Decision and reiterated its request for the match against Zamalek to be replayed.
29. On 15 May 2025, the EFA Appeal Committee issued its decision (previously defined as the “Appealed Decision”), which was notified to Pyramids, Al Ahly and Zamalek on
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the same date. The EFA Appeal Committee declared all appeals inadmissible. The operative part of the Appealed Decision reads as follows:
“Therefore the committee decided:
First: Accept the three appeals in form, as they were submitted within the time limit and the fees were paid.
Second: In the merits of the appeals, the appeals submitted by Al Ahly Sporting Club, Pyramids FC, and Zamalek Sporting Club are inadmissible, due to the finality of the decision issued by the Board of Directors of the First Division Clubs League issued on 30/03/2025
The Committee recommends:
First: Nullify Articles 62 and 63 of the League’s Competitions Regulations in all their paragraphs, as they violate the regulations of the Egyptian Football Association, approved by the FIFA and deprive the Appeals Committee and the Association’s committees in general of the jurisdiction
Second: In cases other than force majeure, the Egyptian Football Association's Competitions Regulations shall be amended by Article 15 paragraph 2/A, B, and Article 17.4 of the Clubs League Regulations regarding withdrawal from the match by deducting six points directly without waiting until the end of the season, in addition to the penalties contained in paragraphs 1 and 3 of Article 15 and 17.8, in order to preserve funds, maintain competitions, and respect the fans.
Third: The First Division Clubs League must take into account the regulations of the Egyptian Football Association, approved by FIFA, when developing the regulations governing its work, in a manner that does not conflict with these regulations.
Fourth: The draw for both the first and second rounds must be held publicly, in the presence of all clubs participating in the tournament, to avoid suspicion.
Fifth: All parties to the sports system and parties of the game must give confidence to the Egyptian arbitration system so that its members can be present in international and continental forums.
Sixth: The clubs that make up the sports system are called upon to uphold the national interest and work to spread the spirit of cooperation and love among them, which will have an impact on the national teams.”
IV. PROCEEDINGS BEFORE THE COURT OF ARBITRATION FOR SPORT
30. On 21 May 2025, Pyramids filed a Statement of Appeal with the CAS against the Appealed Decision, in accordance with Articles R47 and R48 of the 2023 edition of the CAS Code of Sports-related Arbitration (the “CAS Code”), and included EFA, EPL, Al Ahly and Zamalek as the Respondents. In its submission, Pyramids specifically requested for provisional measures and that the matter be submitted to a Sole Arbitrator.
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31. On 22 May 2025, the CAS Court Office acknowledged receipt of Pyramids’ Statement of Appeal. In this letter, the CAS Court Office granted Pyramids a ten-day time limit to file its Appeal Brief and invited the Respondents to state withing five days whether they agreed to the appointment of a Sole Arbitrator. The Respondents were also invited to file their positions regarding the Appellant’s request for provisional measures.
32. On 23 May 2025, EFA informed the CAS Court Office that it would adopt a passive stance during these proceedings.
33. On the same date, Zamalek informed the CAS Court Office that it expressed its support for the appointment of a Sole Arbitrator and Pyramids’ request for provisional measures, whereas EPL and Al Ahly informed the CAS Court Office that they objected to Pyramids’ request for provisional measures. Furthermore, Al Ahly objected to the appointment of a Sole Arbitrator and requested that this case be referred to a three- member Panel, while EPL left the decision regarding the composition of the Panel to the discretion of the CAS.
34. On 27 May 2025, the Deputy President of the CAS Appeals Arbitration Division dismissed the application for provisional measures filed by Pyramids on 21 May 2025.
35. On 4 June 2025, the CAS Court Office referred the issue of the composition of the Panel to the President of the Appeals Arbitration Division pursuant to Article R50 (1) CAS Code.
36. On 16 June 2025, Pyramids submitted its Appeal Brief, in accordance with Article R51 CAS Code.
37. On 17 June 2025, the CAS Court Office acknowledged receipt of Pyramids’ Appeal Brief and invited the Respondents to file their Answers within twenty (20) days.
38. On 7 July 2025, EPL filed its Answer, in accordance with Article R55 CAS Code.
39. On 14 July 2025, Al Ahly filed its Answer, in accordance with Article R55 CAS Code.
40. On 23 July 2025, Zamalek filed its Answer, in accordance with Article R55 CAS Code.
41. On 24 July 2025, the CAS Court Office informed the Parties that EFA did not submit an Answer within the prescribed deadline. Furthermore, the Parties were invited to inform the CAS Court Office whether they preferred a hearing to be held in these proceedings or for the Panel to render an award based solely on the Parties’ written submissions. Additionally, the Parties were invited to inform the CAS Court Office whether they requested a case management conference.
42. On 31 July 2025, Pyramids submitted that it did not consider a hearing to be necessary.
43. On the same date, the CAS Court Office informed the Parties that, pursuant to Article R50 CAS Code, the Deputy President of the CAS Appeals Arbitration Division had decided that the present case would be referred to a three-member Panel.
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44. On 7 August 2025, Pyramids nominated Prof. Dr. Christoph Müller to serve as arbitrator in this matter.
45. On 11 August 2025, Al Ahly nominated Ms Laila El Shentenawi to serve as arbitrator in this matter.
46. On 26 August 2025, the Deputy President of the Appeals Arbitration Division proceeded with the appointment of an arbitrator, as EFA had adopted a passive stance in the proceedings and EPL left the decision regarding the composition of the Panel to the discretion of the CAS. In addition, Al Ahly and Zamalek were unable to agree on a joint nomination. However, given that Zamalek’s position was aligned with that of Pyramids, appointing its nominee jointly with Pyramids would have deprived Al Ahly of a fair opportunity to designate an arbitrator from the CAS list. Consequently, the Deputy President of the Appeals Arbitration Division confirmed the nominations of Prof. Dr. Müller and Ms El Shentenawi as arbitrators.
47. On 9 October 2025, the CAS Court Office informed the Parties that, pursuant to Article R54 CAS Code and on behalf of the Deputy Division President of the CAS Appeals Arbitration Division, the Panel appointed to decide the case was constituted as follows:
President: Mr Frans de Weger, Attorney-at-Law in Haarlem, The Netherlands
Arbitrators: Prof. Dr. Christoph Müller, Professor in Neuchâtel, Switzerland Ms Laila El Shentenawi, Attorney-at-Law in Dubai, United Arab Emirates
48. On 15 October 2025, the CAS Court Office reiterated its request, on behalf of the Panel, whether the Respondents considered a hearing to be necessary.
49. On 16 October 2025, EPL informed the Panel that it would abstain from taking a position on the necessity of a hearing and would defer the matter to the other Respondents and to the Panel’s discretion.
50. On 17 October 2025, Al Ahly indicated that it did not consider a hearing to be necessary.
51. On 3 November 2025, the CAS Court Office informed the Parties, on behalf of the Panel, that the Panel deemed itself sufficiently well-informed to decide this case based solely on the Parties’ written submissions without the need to hold a hearing.
52. On 5 November 2025, the CAS Court Office acknowledged the Order of Procedure duly signed by EPL.
53. On 11 November 2025, the CAS Court Office acknowledged receipt of the duly signed Orders of Procedure of Al Ahly and Pyramids.
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V. SUBMISSIONS OF THE PARTIES AND REQUESTS FOR RELIEF
54. The Panel confirms that it carefully considered in its decision all the submissions, evidence, and arguments presented by the Parties, even if they have not been specifically summarised or referred to in the present arbitral award.
A. The Appellant
55. Pyramids’ submissions, in essence, may be summarised as follows:
Jurisdiction & Admissibility
➢ Pyramids contends that the CAS is competent to deal with the present case. In this regard, Pyramid refers to Article R47 CAS Code, which allows appeals to CAS against decisions of a federation, association or sports-related body, when the status or regulations of the body in question so permit, or when the parties have concluded a specific arbitration agreement, and the appellant has exhausted all internal legal remedies, in accordance with the statutes or regulations of that body.
➢ Pyramids further refers to Article 69 (1) of the EFA Statutes which provides that disputes arising in the association or disputes that may affect its members, leagues, league members, clubs, club members, players, and representatives, may be referred, as a final resort, after exhausting all internal remedies with EFA, to the Egyptian Sports Arbitration and Settlement Center. Its decisions may be appealed before the CAS. Furthermore, Article 69 of the EFA Statutes states that international disputes arising from or in connection with the EFA Statutes, Confédération Africaine de Football (CAF) of FIFA regulations, disputes, or last instance instructions, shall be referred to the CAS, in accordance with CAF and FIFA’s provisions.
➢ Pyramids submits that the EFA Appeal Committee constitutes the highest adjudicatory body within EFA and pursuant to Article 67 (3) of the EFA Statutes, its decisions are final and binding. Accordingly, Pyramids maintains that it has exhausted all available internal remedies.
➢ Additionally, Pyramids states that the Egyptian Sports Arbitration and Settlement Center has been dissolved following a judgement of the Egyptian Constitutional Court rendered on 14 January 2023, which declared its statutes unconstitutional. As a result, the Egyptian Sports Arbitration and Settlement Center should be deemed as ineffective. Pyramids refers to CAS 2022/A/9225, in which the CAS decided that a party may bring a matter directly before the CAS without the necessity of prior resort to the Egyptian Sports Arbitration and Settlement Center.
➢ As to admissibility, Pyramids rejects Al Ahly’s argument that Articles 62 and 63 of the Competition Regulations exclude the right to appeal before any judicial or arbitral body, including the EFA Appeal Committee. Pyramids stresses that this interpretation is incorrect and inconsistent with EPL’s own
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position. The claim by Al Ahly that Pyramids should have appealed directly to the CAS within twenty-one (21) days, bypassing the EFA Appeal Committee, is therefore unfounded. Pyramids submits that the EFA Appeal Committee has the competence to review and, if necessary, overturn EPL’s Second Decision.
➢ Pyramids further notes that both Al Ahly and Zamalek filed appeals against EPL’s Second Decision before the EFA Appeal Committee rather than directly with the CAS. This confirms that both clubs also considered the EFA Appeal Committee to be the competent appellate body to review EPL decisions.
➢ Even assuming that the EFA Appeal Committee lacked jurisdiction, Pyramids submits that an appeal filed in good faith before an instance later deemed incompetent does not prejudice the appellant’s rights, provided that the appeal is subsequently lodged before the proper body within the prescribed time limit after the lack of jurisdiction becomes known.
➢ In any case, the Appealed Decision was received by Pyramids on 15 May 2025, and Pyramids filed its Statement of Appeal on 21 May 2025. Pyramids therefore concludes that it complied with the applicable time limit of twenty- one (21) days, pursuant to Article R49 CAS Code.
Substance
➢ Article 17 (8) of the Competition Regulations provides that: “If a team is deemed to have withdrawn from a match and continues the competition, financial penalties shall be imposed in accordance with the disciplinary and sanctions regulations and quality control system, with the result of the withdrawn match being considered a 3–0 loss in addition to a deduction of three points from its points other than the match which was deemed to be lost.”
➢ According to Pyramids, this provision is crystal clear and leaves no room for deviation. In case a team withdraws from a match but continues to participate in the competition, apart from the 0-3 defeat and the financial penalties, an additional three points are to be deducted. Pyramids submits that these sanctions are cumulative and not optional. EPL was therefore required to impose all of them.
➢ The relevant facts are undisputed: Al Ahly deliberately decided not to appear for its scheduled match against Zamalek, and subsequently continued to participate in the Nile League. Accordingly, Al Ahly must be sanctioned not only with a 0–3 defeat and financial penalties, but also with a three-point deduction under Article 17 (8) of the Competition Regulations.
➢ EPL justified its decision to remove the three-point deduction by invoking Article 63 (2) of the Competition Regulations, claiming that the short time between the scheduling of the final stage and the Zamalek–Al Ahly match constituted a force majeure or emergency event. Pyramids rejects this
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reasoning as artificial and contrary to the plain meaning of Article 17. (8) of the Competition Regulations. The threshold for force majeure is exceptionally high. According to the Competition Regulations, it requires “unforeseen and uncontrollable events” such as “abnormally severe weather, earthquakes, terrorist acts, or military operations”.
➢ Pyramids further refers to the jurisprudence of the Egyptian Court of Cassation, which has consistently held that, for an event to qualify as force majeure, it must be both unforeseeable and impossible to avert. If either condition is not met, the event cannot constitute force majeure.
➢ The intentional and publicly declared refusal by Al Ahly to participate in a pre-scheduled match cannot conceivably be regarded as a force majeure or emergency event. Such conduct was fully within Al Ahly’s control and entirely foreseeable. Moreover, the competition format and the timing of the final stage were known to all clubs well in advance.
➢ Furthermore, Al Ahly had no entitlement to the appointment of foreign referees under any applicable regulation. The EOC expressly confirmed this in its decision. The EFA Appeal Committee had also previously found that Al Ahly did not object to the match schedule and failed to comply with the procedure for requesting foreign referees under Article 46 (12) of the Competition Regulations. Even if it had complied, EFA retained full discretion to reject such requests. Finally, Article 46 (3) of the Competition Regulations expressly prohibits clubs from objecting to the appointment of referees once made.
➢ Pyramids highlights that EPL has previously applied Article 17 (8) of the Competition Regulations strictly and consistently. For instance, in June 2024, when Zamalek refused to appear for a scheduled match against Al Ahly, the EPL immediately sanctioned Zamalek with a 0–3 defeat and a three-point deduction.
➢ By contrast, in the present case, EPL’s subsequent reversal of its First Decision and removal of the three-point deduction constitutes a clear act of venire contra factum proprium. Both Al Ahly and EPL had expressly committed in writing to abide by the decision of the EOC, which confirmed EPL’s First Decision. Their later conduct in contradicting this undertaking violates the fundamental principle of good faith and legal certainty recognised under Swiss law and CAS jurisprudence.
➢ Pyramids submits that the EFA Appeal Committee erred in declaring the appeals inadmissible, on the ground that EPL allegedly had exclusive competence to decide on force majeure or emergency situations.
➢ Excluding judicial review of administrative decisions is contrary to both Egyptian and Swiss constitutional principles. Article 97 of the Egyptian Constitution provides: “Litigation is a safeguarded right guaranteed to all. It is forbidden to grant any act or administrative decision immunity from judicial
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oversight”. Therefore, any rule purporting to immunize EPL decisions from review is null and void as a matter of Egyptian constitutional law.
➢ The Competition Regulations themselves provide that disciplinary and appeal procedures are governed by the regulations of both EFA and EPL. Article 58 (6) of the Competition Regulations stipulates that decisions of the EPL Competitions Administration are final and enforceable unless otherwise decided by the EFA Appeal Committee or the CAS. Accordingly, the EFA Appeal Committee has jurisdiction to review EPL decisions, including EPL’s Second Decision.
56. On this basis, Pyramids submitted the following requests for relief in its Appeal Brief:
“(1) To confirm the first decision rendered by Respondent 2 dated 15 March 2025, which concluded that (i) Respondent 4 wins the match against Respondent 3 of 11 March 2025 by 3-0, that (ii) three (3) additional points shall be deducted from Respondent 3 at the end of the 2024/2025 season of the Egyptian Premier League and (ii) that Respondent 3 is charged with financial penalties and liabilities from the loss of expected revenue from commercial rights
(2) To order Respondent 1 jointly with Respondent 2 to execute/re-instate the first decision rendered by the Board of Directors of Respondent 2 dated 15 March 2025.
(3) To declare null and void the decision of the Appeals Committee of Respondent 1 dated 15 May 2025 and accordingly the decision of Respondent 2 dated 30 March 2025, which concluded not to deduct three (3) points from Respondent 3 at the end of the 2024/2025 season of Egyptian Premier League.”
(4) To order the Respondents 1-3 to bear all costs of the arbitration proceedings (including the preceding provisional measures proceedings), including costs and expenses of the CAS and the arbitrators, and to compensate Appellant for its legal fees and all other expenses incurred in connection with the appeal proceedings.”
B. The First Respondent
57. The First Respondent did not file an Answer.
C. The Second Respondent
58. EPL’s submissions, in essence, may be summarised as follows:
➢ EPL’s defence is structured in two parts (1) the principal defence and (2) the alternative defence.
Principal defence
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➢ EPL’s principal defence is based on the fact that the Appealed Decision in the present case was not issued by EPL, but rather by another independent body — the EFA Appeal Committee. Accordingly, EPL argues that it lacks standing to be named as a Respondent in these proceedings. It follows, in EPL’s view, that all relief sought in relation to any EPL decision, specifically reliefs nos. 3 and 4 of the Statement of Appeal, should be declared inadmissible.
➢ The EFA Appeal Committee, in its Appealed Decision, explicitly declared that it lacked jurisdiction to examine the Appeal submitted by Pyramids on 2 April 2025. Consequently, EPL submits that the only issue before the CAS is whether the EFA Appeal Committee correctly declined jurisdiction. That leads to two possible outcomes: the CAS confirms that the EFA Appeal Committee indeed lacked jurisdiction, or the CAS finds that the EFA Appeal Committee did have jurisdiction. In the latter case, EPL maintains that the CAS should limit itself to recognising such jurisdiction and remit the matter to the EFA Appeal Committee for a decision on the merits. EPL contends that it would be procedurally improper and contrary to the hierarchy of adjudication for the CAS to address the merits of EPL’s decisions directly, as this would deprive the EFA Appeal Committee of its right to exercise its own competence in the first instance.
➢ In light of the foregoing, EPL submits two preliminary objections: (i) EPL lacks standing to be named as a Respondent in proceedings concerning a decision it did not issue; and (ii) Pyramids’ requests targeting EPL’s Second Decision fall outside the scope of this arbitration.
➢ EPL submits that, as a matter of Egyptian law — which governs these proceedings — a claim must be directed only against a party that has legal standing in the matter. Otherwise, the claim must be dismissed as inadmissible, as this constitutes a matter of public policy. Since the Appealed Decision was rendered by the EFA Appeal Committee, not by EPL, EPL cannot be held responsible for it. EPL therefore requests the CAS to declare the appeal inadmissible in respect of EPL.
➢ Furthermore, EPL maintains that EPL’s Second Decision is not part of the present appeal. Pyramids never appealed EPL’s Second Decision within the twenty-one (21) day deadline prescribed under Article R49 CAS Code. Consequently, that decision lies outside the jurisdiction of the CAS. Only the Appealed Decision of the EFA Appeal Committee is within the scope of these proceedings. Accordingly, EPL requests the CAS to declare Pyramids’ requests concerning the merits — specifically reliefs nos. 3 and 4 — inadmissible.
Alternative defence
➢ Should the CAS find that EPL has standing in these proceedings, the Appeal must still fail on the followings grounds: (i) Pyramids has no actual and direct legal interest to challenge EPL’s Second Decision; and (ii) EPL’s Second Decision was a lawful, proportionate and justified measure.
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➢ EPL submits that Pyramids has no actual and direct legal interest in filing this appeal. Under Egyptian law, the Egyptian Court of Cassation has defined “actual interest” as follows: “Litigation presupposes a dispute over the right in question, such that the claimant has a legally recognised interest in suing the defendant for the requested relief, as described in Article 3 of the Code of Civil and Commercial Procedure”.
➢ CAS jurisprudence also requires an appellant to demonstrate a direct, personal, and legitimate interest in the contested decision. Standing cannot arise from mere dissatisfaction or indirect consequences. CAS panels have consistently held that a person who is only “remotely affected” by a decision has no capacity to appeal it. The “actual interest” must exist both at the time of the decision and at the time of filing the appeal (CAS 2020/A/6922).
➢ Pyramids was not involved in the underlying disciplinary matter. EPL’s Second Decision imposed no sanctions, obligations, or adverse effects on Pyramids. The decision related solely to Al Ahly and its conduct during the match against Zamalek.
➢ On 30 March 2025, the date of EPL’s Second Decision, the Nile League standings showed Pyramids in first place, with seven matches still to be played by each team. Therefore, Pyramids cannot claim that it suffered any actual damage or disadvantage at that point. Any alleged harm is speculative and insufficient to establish standing. For these reasons, EPL requests the CAS to declare the appeal inadmissible for lack of actual and direct interest.
➢ EPL submits that EPL’s Second Decision was a lawful and proportionate administrative act, adopted pursuant to Article 63 of the Competition Regulations, following a formal grievance lodged by Al Ahly concerning exceptional scheduling and logistical constraints related to the 11 March 2025 match against Zamalek.
➢ Article 63 (2) of the Competition Regulations grants EPL authority to interpret and apply the regulations in cases of exceptional or unforeseen circumstances. EPL properly exercised this delegated authority.
➢ Contrary to Pyramids’ allegations, EPL clarifies that it did not classify the events of 11 March 2025 as “force majeure” or “emergency events” within the meaning of the Competition Regulations. Instead, EPL acknowledged the existence of exceptional and extenuating circumstances that warranted a proportionate adjustment of the sanctions. These circumstances included:
• Compressed scheduling due to the new Nile League format and restructuring;
• Overlapping administrative deadlines causing regulatory delays;
• A request for foreign referees submitted less than two weeks before the match, in violation of EFA Referee Committee procedures; and
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• Intervention by the Minister of Sports seeking to facilitate foreign referees, ultimately rejected by the EFA Referee Committee.
➢ EPL emphasizes that it does not condone Al Ahly’s refusal to play and acknowledges that it constituted a breach of the Competition Regulations. EPL, however, sought to apply a measured and proportionate sanction, balancing regulatory integrity with fairness and the specific context. Accordingly, EPL maintained the 3–0 forfeit and financial penalties originally imposed but removed the additional three-point deduction as a discretionary act of leniency in light of the exceptional circumstances and Al Ahly’s previously clean disciplinary record.
➢ CAS jurisprudence recognises the autonomy of sports governing bodies to regulate and discipline their competitions, provided such discretion is exercised in accordance with the principle of proportionality. EPL asserts that it fully respected these principles by weighing the relevant facts, the exceptional context, and the need to preserve competitive balance and fairness. EPL therefore submits that EPL’s Second Decision was regular, lawful, and fully compliant with the Competition Regulations and the principles of sports governance.
➢ Finally, EPL argues that there is no causal link between EPL’s Second Decision and Pyramids’ alleged loss of the Nile League title. The removal of the three-point deduction did not, in itself, determine the championship outcome. Following EPL’s Second Decision, Pyramids remained in first place in the standings. The eventual outcome of the competition was determined solely by on-field performance in the remaining matches. Pyramids has not demonstrated that the non-deduction of three points from Al Ahly directly or decisively altered the final ranking.
➢ Accordingly, EPL respectfully submits that Pyramids has failed to meet the threshold for annulment and requests the CAS to dismiss the appeal in its entirety.
59. EPL submitted the following requests for relief in its Answer:
“Principally:
1) Declare the Appeal inadmissible against the Second Respondent for lack of standing; and
2) Declare the relief sought by the Appellant no. 3 and 4 in its Brief of Appeal inadmissible as they do not fall within the scope of this Appeal
Alternatively
1) Declare the Appeal inadmissible in its entirety as the Appellant lacks direct and actual interest
Alternatively
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1) Declare that the Second Decision was in conformity with the applicable laws and regulations;
2) Declare that the Second Decision caused no harm to the Appellant; and
3) Reject the Appeal.
And in all cases
Declare that the Appellant should bear all the arbitration and legal cost and compel it to compensate the Second Respondent for the legal costs it had to endure, subject, of course, to the acceptance of the Arbitral Panel to the submission on cost.”
D. The Third Respondent
60. Al Ahly’s submissions, in essence, may be summarised as follows:
Jurisdiction & Admissibility
➢ Al Ahly does not contest the jurisdiction of the CAS to adjudicate the present dispute. This is consistent with Articles 63 and 69 of the EFA Statutes, as well as Article 63 of the Competition Regulations.
➢ Al Ahly notes that Pyramids claims to have a substantial sporting and financial interest in seeking CAS adjudication, allegedly to be declared the 2024/2025 Nile League champion. However, Al Ahly respectfully submits that the present appeal is without merit and represents a final, unfounded attempt by Pyramids to obtain through litigation what it failed to achieve on the pitch.
➢ Following the issuance of the EPL’s Second Decision, Pyramids remained at the top of the league standings, holding a four-point lead with seven matches left in the Championship Group Final Stage. There exists no causal link between the contested decision and Pyramids’ eventual failure to win the league. The outcome of the competition was determined solely by sporting performance, not by any regulatory or administrative act.
➢ CAS jurisprudence firmly establishes that only parties directly and adversely affected by a decision have standing to appeal. The distinction between direct and indirect interest is material and must be assessed in light of the specific circumstances of each case.
➢ In this regard, CAS precedents such as CAS 2008/A/1583 & 1584 confirm that purely competitive effects — i.e., consequences arising only from a party’s status as a competitor of the addressee of a challenged decision — do not amount to a direct legal interest. Such effects are merely indirect and therefore do not confer standing.
➢ Similarly, in CAS 2007/A/1278 & 1279, the Panel held that a club not directly involved in the re-evaluation of a match lacked standing to challenge
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it, even if the result could affect league standings. The Panel found the impact to be collateral, not direct — and therefore insufficient to establish standing.
➢ Pursuant to Article 67 of the EFA Statutes, the EFA Appeal Committee has jurisdiction only over disciplinary and ethics matters originating from the EFA Disciplinary and Ethics Committee. Its competence is limited to non- final decisions issued within that framework.
➢ EPL’s Second Decision was not issued by the EFA Disciplinary or Ethics Committees; it was rendered by the EPL Board of Directors pursuant to Article 63 (2) of the Competition Regulations, which explicitly provides that such decisions “are final and binding and may not be challenged or appealed before any judicial or arbitration body.”
➢ Therefore, the EFA Appeal Committee lacked jurisdiction to review EPL’s Second Decision, as the latter did not originate from a disciplinary or ethics proceeding.
➢ Contrary to the Pyramids’ contention, Al Ahly was under no obligation to appeal EPL’s Second Decision before the EFA Appeal Committee prior to resorting to the CAS. The relevant time limit for appeal began upon notification of EPL’s Second Decision. Any erroneous recourse to an internal remedy cannot suspend, interrupt, or extend the applicable time limit under Article R47 of the CAS Code.
➢ Regarding Pyramids’ claim that Al Ahly’s stance on EFA jurisdiction is inconsistent, Al Ahly clarifies that its appeal of 15 March 2025 concerned EPL’s First Decision, which was disciplinary in nature. Under Article 67 of the EFA Statutes, the proper appellate body for such a decision was indeed the EFA Appeal Committee. Al Ahly therefore lawfully exercised its right of appeal. It is thus inaccurate to suggest that Al Ahly challenged the jurisdiction of the EFA Appeal Committee in that instance.
➢ In light of the foregoing, Pyramids’ Appeal is inadmissible. Pyramids should have directly appealed the EPL’s Second Decision before the CAS within twenty-one (21) days of notification, as that decision was final and binding under Article 63 of the Competition Regulations.
➢ Furthermore, Pyramids’ argument that Article 63 of the Competition Regulations unlawfully excludes judicial review is misplaced. Under Article R58 of the CAS Code, the Panel must decide according to the applicable regulations. Article 63 of the Competition Regulations clearly and lawfully provides that EPL decisions issued under that article are final and not subject to appeal.
➢ Consistent with CAS 2021/A/6312, the Panel’s de novo review power under Article R57 CAS Code does not extend to overturning a finding of lack of jurisdiction by an internal judicial body. The mere consent of the parties to
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CAS jurisdiction does not authorize a substantive review where the internal body — in this case, the EFA Appeals Committee — has ruled that it lacked competence.
➢ Accordingly, since the EFA Appeal Committee determined that it lacked jurisdiction to hear the appeal against the EPL’s Second Decision, this Panel’s scope of review is confined to that finding. The Appeal must therefore be dismissed.
Substance
➢ At the outset, it is essential to distinguish between a force majeure event and an emergency event. Pyramids conflates the two, relying erroneously on jurisprudence related to Force Majeure. However, under the Competition Regulations, these are distinct legal concepts. EPL’s Second Decision was rendered pursuant to Article 63 (2) of the Competition Regulations, which governs emergency events, not force majeure.
➢ The EPL’s Second Decision demonstrates that the EPL Board of Directors acted within the scope of Article 63 (2) of the Competition Regulations, acknowledging the existence of exceptional circumstances amounting to an Emergency Event.
➢ Al Ahly lawfully exercised its right to request foreign referees. However, due to scheduling and logistical constraints — as recognized in EPL’s Second Decision — it was objectively impossible to fulfil this request. These conditions fall squarely within the meaning of an emergency event under Article 63(2) of the Competition Regulations.
➢ EPL acknowledged that Al Ahly’s request was legitimate and that the inability to appoint foreign referees was not due to negligence or unwillingness, but to scheduling and operational pressures resulting from the competition’s format.
➢ Moreover, the communications and public statements issued by Al Ahly demonstrate that the club did not intend to withdraw from the match but rather sought procedural fairness by requesting either the appointment of foreign referees or a reasonable postponement — both legitimate remedies under the regulations.
➢ Accordingly, EPL’s Second Decision was issued within the authority granted by Article 63 of the Competition Regulations, duly conferred by the General Assembly. The decision reflected procedural fairness and regulatory consistency. Article 17 (8) of the Competition Regulations is therefore not applicable.
➢ Pyramids comparison with the 2023/2024 Zamalek incident is both factually and legally misplaced. That case involved a deliberate refusal to play as a
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protest against prior refereeing decisions — conduct entirely distinct from the present matter.
➢ Al Ahly did not refuse to participate in the match; it exercised a procedural right to request foreign referees and sought a postponement in good faith. Its actions cannot be equated to a wilful withdrawal.
➢ Furthermore, the regulatory framework governing the 2024/2025 season — particularly regarding Emergency Events and scheduling — differs materially from that of the prior season. Consequently, the Zamalek precedent is not applicable.
➢ Pyramids attempt to analogize the two cases disregards the factual, regulatory, and procedural distinctions between them. Imposing identical sanctions under dissimilar circumstances would contravene fundamental principles of proportionality and fairness.
61. EFA submitted the following requests for relief in its Answer:
“Primary Relief
1. Declare the appeal inadmissible on the grounds of the Appellant’s lack of legal standing and absence of a legitimate interest
Subsidiary Relief
2. Declare the appeal inadmissible due to the Appellant’s failure to exhaust the right remedies in accordance with the applicable regulations and CAS Code. In the Alternative, and only in the Event the Panel/Sole Arbitrator Considers the Appeal Admissible – On the Merits
3. Confirm that the scope of the Panel’s review is limited to assessing the jurisdiction of the AC EFA, as set out in the Decision under Appeal.
4. Dismiss the appeal in its entirety as unfounded, given the Appellant’s failure to demonstrate any violation of the applicable regulatory framework or to justify the reliefs sought;
5. Confirm the validity and enforceability of (i) the EPL Second Decision issued on 30 March 2025 and (ii) the Decision Under Appeal issued on 15 May 2025; In any event
6. Order the Appellant to bear all costs of the arbitration proceedings, including the CAS administrative costs, provisional measures submissions and the Arbitrators ‘fees;
7. Order the Appellant to pay a contribution towards the Third Respondent’s legal fees and other expenses incurred in connection with these proceedings, in an amount to be determined by the Panel at its discretion.”
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E. The Fourth Respondent
62. Zamalek’s Answer essentially aligns with the arguments set out in Pyramids’ Appeal Brief and shall therefore here be deemed incorporated and considered accordingly.
63. On this basis, Zamalek submitted the following requests for relief in its Answer:
“i) To accept the Appellant’s appeal;
ii) To annual the EFA Appeals Committee decision dated May 15, 2025;
iii) To annul the decision issued by the Board of Directors of the Egyptian Professional Clubs Association on March 30,2025;
iv) To confirm and uphold the validity of the Competitions Committee’s Decision No. 50 issued on 15 March 2025 and To order Respondents 1 and 2 jointly to execute the decision;
v) CAS to order EFA, EPL, and/or Al Ahly to pay Zamalek all costs, including arbitration and administrative, compensation, legal fees and contribution in connection with this case.”
VI. JURISDICTION
64. Article R47 (1) of the CAS Code provides as follows:
“An appeal against the decision of a federation, association or sports-related body may be filed with CAS if the statutes or regulations of the said body so provide or if the parties have concluded a specific arbitration agreement and if the Appellant has exhausted the legal remedies available to it prior to the appeal, in accordance with the statutes or regulations of that body.”
65. As the Appealed Decision concerns a decision of EFA’s Appeal Committee, the Panel finds that in order to address the jurisdiction of the CAS, reference must be made to the statutes and regulations of EFA.
66. In this regard, Article 67 of the EFA Statutes provides as follows:
“The decisions of the EFA Appeal Committee shall be final and binding for all concerned parties. They may not be appealed within EFA.”
67. Article 69(1) of the EFA Statutes, further provides:
“1) Disputes arising in the association or disputes that affect its members, leagues, league members, clubs, club members, players, and representatives, may be referred to the Egyptian Arbitrations and Settlement Center if its competence is contractually agreed upon, which shall finally settle the dispute, given that all internal remedies have been exhausted. The decision of the Egyptian Arbitration and Settlement Center shall be final, and away from the competent courts, unless prohibited by Egyptian Law. The decision shall be appealed before CAS.
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2) International disputes that arise out of or in connection with this regulation or CAF or FIFA regulations, decisions, or last minute instructions, shall be referred to CAS, in accordance with CAS and FIFA’s provisions.”
68. The Panel further notes that none of the Respondents argued that the CAS lacked jurisdiction.
69. It follows that the CAS has jurisdiction to decide on the present dispute.
VII. ADMISSIBILITY
70. Article R49 CAS Code reads as follows:
“In the absence of a time limit set in the statutes or regulations of the federation, association or sports-related body concerned, or in a previous agreement, the time limit for appeal shall be twenty-one days from the receipt of the decision appealed against.”
71. The Panel notes that the EFA statutes and or regulations do not set out a time limit within which an appeal must be lodged before the CAS.
72. In addition, the Parties did not refer to a provision in the EFA statutes or regulations providing a deadline to file an appeal with the CAS, nor disputed the admissibility of the appeal as filed by Pyramids as a result of exceeding a regulatory deadline provided by the EFA statutes or regulations.
73. In the absence of a time limit set in the statutes or regulations of EFA, the Panel finds that the time limit of twenty-one (21) days as set by Article R49 CAS Code applies.
74. In that regard, the Appealed Decision was received by Pyramids on 15 May 2025, and Pyramids filed its Statement of Appeal on 21 May 2025. Therefore, the appeal was filed within the deadline of twenty-one (21) days set by Article R49 CAS Code.
75. Furthermore, the appeal complied with all other requirements of Article R48 CAS Code.
76. Consequently, it follows that the appeal is admissible.
VIII. APPLICABLE LAW
77. Article R58 CAS Code provides as follows:
“The Panel shall decide the dispute according to the applicable regulations and, subsidiarily, to the rules of law chosen by the parties or, in the absence of such a choice, according to the law of the country in which the federation, association or sports-related body which has issued the challenged decision is domiciled or according to the rules of law that the Panel deems appropriate. In the latter case, the Panel shall give reasons for its decision”.
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78. Considering the above, the Panel is satisfied that the dispute shall be decided primarily according to the statutes and various “applicable regulations” of EFA and EPL. The subsidiarily applicable law, in so far as relevant, is the law of Egypt, as EFA has its registered seat in that country.
IX. MERITS — A. The Main Issues
79. The Panel observes that several legal issues were raised by the Parties, in particular in relation to i) Pyramids’ standing to appeal, ii) EPL’s and Zamalek’s standing to be sued, iii) the jurisdiction of the EFA Appeal Committee, and (iv) the legality of EPL’s Second Decision. In this regard and for the avoidance of any doubt, the Panel emphasises that all these issues are related to the merits. In fact, pleas relating to a lack of standing to appeal or standing to be sued, are – according to settled jurisprudence of the CAS (cf. CAS 2009/A/1869; CAS 2015/A/3959; CAS 2015/A/4131) and the Swiss Federal Tribunal (the “SFT”) (see SFT 128 II 50, 55) – questions related to the merits of the case. Similarly, which is an important part of Pyramids’ and Al Ahly’s submissions, the question whether or not the EFA Appeal Committee correctly determined that it lacked jurisdiction to hear the appeal against EPL’s Second Decision, is also an issue of merits. In this regard, and again to avoid any misunderstanding, the Panel notes that if a party appeals against a decision issued by a second-instance organ of an international federation, i.e. the EFA Appeal Committee, questions relating to the jurisdiction of such body become questions on MAVROMATI/REEB, The Code of the Court of Arbitration for Sport, 2025, p. 575).
80. It is relevant to mention that all the legal issues raised are related to the merits as the Panel is free to determine how to address the sequence of the different substantive questions at stake in legal proceedings, which approach is also consistent with CAS jurisprudence (CAS 2016/A/4903, para 882 of the abstract published on the CAS website; see also CAS 2017O/5264-5266, para. 189). Accordingly, the Panel wishes to clarify that the issues of standing do not necessarily have to be addressed first, also having in mind that the Panel will conclude, as will be extensively motivated in the next paragraphs, that the EFA Appeal Committee correctly determined that it lacked jurisdiction to hear the appeal against EPL’s Second Decision, which makes that the other legal issues, including the issue of standing, do not need to be dealt anymore.
81. Therefore, and against the above legal background concerning the Panel’s discretion to address the legal issues in the order it deems appropriate, under the circumstances, the Panel will proceed directly to the question whether the EFA Appeal Committee correctly decided that it had no jurisdiction to hear Pyramids’ appeal lodged against EPL’s Second Decision, also because this issue lies at the heart of the Appealed Decision as this constituted the ground on which Pyramids’ appeal was dismissed.
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Jurisdiction of the EFA Appeal Committee
82. In the case at hand, Pyramids and Al Ahly hold opposing views as to the jurisdiction of the EFA Appeal Committee. The Panel briefly recalls the main points of their respective positions.
83. According to Pyramids, the EFA Appeal Committee did have jurisdiction to rule over EPL’s Second Decision, inter alia, because Al Ahly never previously questioned the jurisdiction of the EFA Appeal Committee and Al Ahly and Zamalek also filed appeals against that decision before the EFA Appeal Committee. In this context, Pyramids relies on the principles of estoppel and venire contra factum proprium. Pyramids further submits that it acted in good faith by filing its appeal before the EFA Appeal and that no adverse consequence should follow, given that it acted diligently by lodging an appeal with the CAS immediately after the EFA Appeal Committee declined jurisdiction. On that basis, Pyramids argues that the time limit under Article R49 CAS Code should be reinstated.
84. In addition, Pyramids submits that it cannot be legally permissible for the EPL to adopt a decision that is entirely immune from appeal. Pyramids refers to Article 58.6 of the Competition Regulations, arguing that although decisions of the EPL Competition Administration are described as final and enforceable, this is “unless otherwise decided by both the EFA Appeal Committee and CAS”. Pyramids highlights that EPL has previously applied Article 17(8)of the Competition Regulations strictly and consistently. For instance, in June 2024, when Zamalek refused to appear for a scheduled match against Al Ahly, EPL immediately sanctioned Zamalek with a 0–3 defeat and a three-point deduction.
85. Al Ahly, on the other hand, submits that Article 67 of the EFA Statutes clearly limits the jurisdiction of the EFA Appeal Committee to appeals filed against decisions issued by the EFA Disciplinary and Ethics Committee. In this regard, Al Ahly argues that the underlying decision in the present case was adopted by the EPL Board of Directors and not by the EFA Disciplinary or Ethics Committee. Moreover, according to Al Ahly, Article 63.2 of the Competition Regulations expressly provides that such decisions are final and binding and thus triggered the twenty-one (21)-day time limit under Article R49 CAS Code, so Pyramids’ decision to file an appeal before the EFA Appeal Committee was procedurally unnecessary and cannot be invoked to suspend the time limit for appealing the final decision.
86. Having the above positions in mind, and after a thorough examination of the applicable statutes and regulations of EFA and EPL, the Panel does not follow Pyramids on this point and finds that the EFA Appeal Committee correctly declined jurisdiction. Indeed, as rightly submitted by Al Ahly, the Panel is not able to pinpoint any regulatory basis in the statutes and regulations of either EFA or EPL authorising the EFA Appeal Committee to rule over decisions taken by the EPL Board of Directors. The Panel will explain as follows.
87. First, the Panel notes that the underlying decision challenged before the EFA Appeal Committee was taken by the EPL Board of Directors. In this respect, the Panel refers to Article 63(2) of the Competition Regulations, which clearly provides that: “EPL’s
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Board of Directors shall have the authority to make decisions in cases of Force Majeure Or Emergency Circumstances. Such decisions shall be final and binding and may not be challenged or appealed before any judicial or arbitration”. The Panel considers the wording of this provision clear and unequivocal: decisions of the EPL Board of Directors taken in cases of force majeure or emergency circumstance are final, binding and not subject to appeal.
88. Second, Article 63(3) of the Competition Regulations further stipulates that the EPL Board of Directors “shall have the right to interpret the articles of these Regulations, and such interpretations may not be challenged or appealed before any judicial or arbitration body.” In other words, it was exclusively for the EPL Board of Directors to determine whether the circumstances surrounding the match of 11 March 2025 between Al Ahly and Zamalek constituted force majeure or emergency circumstances.
89. It was also for this reason that the EFA Appeal Committee held the following (underlined text made by the Panel):
“Based on the above […] the Appeals Committee have their hands tied regarding the decision issued on 30/03/2025 by the Board of Directors of the First Division Clubs League, which prompted it to summon the Director of the Competitions Department of the League, Mr. Taha Ezzat, to clarify the important points in the regulations and the decisive factors in the matter of the three appeals, who supported what was stated in those texts of the newly created articles, and that the League’s Board of Directors is the one that has the right to interpret the articles of the amended regulations and used its powers contained therein which all participating clubs were informed of when the regulations were distributed to them on 19/10/2024 before the draw was held without any objection to what the statements contained.”
90. In this context, the Panel agrees with the EFA Appeal Committee that its “hands were tied” regarding EPL’s Second Decision, noting that the power and competence to interpret and apply the relevant regulatory provisions was expressly vested in the EPL Board of Directors. The Parties, including Pyramids, had been duly informed by the EPL General Assembly on 17 October 2024 of these new provisions into the amended Competition Regulations for the 2024/2025 season and raised no objection at that relevant time. Accordingly, so the Panel finds, Pyramids cannot at this stage successfully argue that the exclusion of judicial review of EPL’s Second Decision is impermissible. Similarly, Pyramids cannot rely on what occurred in the 2023 – 2024 season with respect to Zamalek, as the regulatory framework applicable during that season did not contain Articles 62 and 63 of the Competition Regulations. The EFA Appeal Committee further correctly stated that (underlined text made by the Panel):
“It is legally stipulated that it is not permissible to excuse ignorance of the law or regulations, and it is not permissible to deprive the League’s Board of Directors of the right granted to it by the Clubs which have the right to approve in addition to their lack of objection to the amended regulations for the 2024/2025 season. Based on the above, the decision issued by the Board of Directors of the Egyptian Clubs League on 30/03/2025 is a final decision and cannot be objected to or appealed before any judicial or arbitration body, as stated in the amended regulations for
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the 2024-2025 season competition regulations, which the clubs had the right to object to at the time. In addition, the association gave itself the right to assess force majeure and emergency circumstances, and therefore the Appeals Committee was prevented from considering these appeals.”
91. The Panel indeed notes that the EFA Appeal Committee additionally recommended to: “[n]ullify articles 62 and 63 of the League’s Competitions Regulations in all their paragraphs, as they violate the regulations of the Egyptian Football Association ”. However, the Panel’s de novo review power under Article R57 CAS Code does not extend to amending or abolishing EPL’s regulations in the present proceedings. Even assuming that certain provisions were invalid, which is not demonstrated by the Appellant, the Panel’s role is limited to assessing their applicability to the present case, their compatibility with sporting-merits principles and other statutory provisions, and – importantly – their conformity with public policy, the principle of ne ultra/ne infra petita, and the Parties’ right to be heard (MAVROMATI/REEB, The Code of the Court of Arbitration for Sport, 2025, p. 576).
92. The Panel does further not agree that its de novo powers, as was also submitted by Pyramids, can break through the Appealed Decision as the CAS is not competent to review an underlying decision which was reviewed by a body that had already correctly declared itself incompetent (see, inter alia, CAS 2021/A/6312). In this respect, so the Panel finds, the de novo powers of review cannot be broader than that of the appellate body – in this case the EFA Appeal Committee. Put differently, the CAS panel’s jurisdiction on appeal is limited to issues that fell within the jurisdiction of the previous instance and/or were addressed by it (MAVROMATI/REEB, The Code of the Court of Arbitration for Sport, 2025, p. 574–575; see, inter alia, CAS 2021/A/8312). Since the merits of EPL’s Second Decision were outside the jurisdiction of the EFA Appeal Committee, they equally fall outside the Panel’s jurisdiction in the present appeal.
93. With regard to Article 58(6) of the Competition Regulations and Pyramids’ position that this provision offers a route to the EFA Appeal Committee, the Panel considers that this provision concerns “protests” and Pyramids has not demonstrated why its filing would qualify as such rather than an appeal. Moreover, Article 58.6 of the Competition Regulations applies to decisions of the EPL Competition Management, whereas EPL’s Second Decision was issued by the EPL Board of Directors. Therefore, also on this basis, the Panel does not see a path for an appeal to the EFA Appeal Committee.
94. Further to this, the Panel notes that the EFA Statutes likewise do not foresee that decisions of the EPL Board of Directors may be appealed to the EFA Appeal Committee. As a matter of fact, the Panel agrees with Al Ahly that Article 67(2) of the EFA Statutes is very clear in this matter:
“The Appeal Committee shall be responsible for hearing appeals filed against decisions issued by the Disciplinary and Ethics Committee that have not been deemed final in accordance with EFA regulations .”
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95. The Panel brings to mind that the EPL’s Second Decision was issued by the EPL Board of Directors and not by the EFA Disciplinary or Ethics Committee. Accordingly, it falls outside the scope of the appeal competence of the EFA Appeal Committee previously defined by Article 67 of the EFA Statutes. So, neither the EPL nor the EFA regulations provide for an appeal to the EFA Appeal Committee against EPL’s Board of Directors’ decisions.
96. Finally, the Panel finds that Pyramids could not reasonably rely on a good faith assumption of jurisdiction where the regulatory framework contains no basis for such jurisdiction. As set out above, it is clear to the Panel that the regulatory framework did not contain any basis for jurisdiction. In the Panel’s view, the fact that Al Ahly and Zamalek also filed an appeal before the EFA Appeal Committee back then does not cure the absence of any legal basis. In that light, the EFA Appeal Committee’s conclusion that it lacked jurisdiction did not reinstate the twenty-one (21)-day time limit under Article R49 CAS Code. The CAS only exceptionally accepts a delay where the delay, for example, is caused by the sports body that rendered the decision (MAVROMATI/REEB, The Code of the Court of Arbitration for Sport, 2025, p. 477; see, inter alia, CAS 2024/A/10474). In the present case, however, the Panel finds that such exception does not apply as the Appellant, so the Panel observes, alleges bad faith from the side of Al Ahly – not in particularly by the EPL or EFA – in order to support is position that the 21-day time limit under Article R49 CAS Code must be reinstated. Likewise, it is also not found relevant by the Panel that Al Ahly never previously questioned the jurisdiction of the EFA Appeal Committee as it was the EFA Appeal Committee that made the decision on an ex officio basis that it lacked jurisdiction to hear the appeal. Regardless of whether this was not raised by Al Ahly in the previous proceedings before the EFA Appeal Committee, the Panel had to make its own assessment whether or not the EFA Appeal Committee correctly determined that it lacked jurisdiction, which was the case, as set out before.
B. Conclusion
97. Based on the foregoing, and after having taken into due consideration all the specific circumstances of the case, the evidence produced and the arguments submitted by the Parties, the Panel concludes that the EFA Appeal Committee correctly determined that it had no jurisdiction. Consequently, the Appeal filed by Pyramids must be dismissed and the Appealed Decision is upheld.
98. Given the Panel’s findings on the issue of the lack of jurisdiction of the EFA Appeal Committee, and for further sake of clarity, the Panel does not consider it necessary, as set out before, to make a final determination as to the other substantive issues that are at stake under the merits. Now that the Panel has ruled that the EFA Appeal Committee correctly determined that it lacked jurisdiction to hear the appeal, the answer as to the other legal issues, such as the issue of standing, will not have any decisive effect on the outcome in the present proceedings.
99. All other and further motions or prayers for relief are dismissed.
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X. COSTS
(…)
*********
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ON THESE GROUNDS
The Court of Arbitration for Sport rules that:
1. The appeal filed by Pyramids FC against the decision of the EFA Appeal Committee issued on 15 May 2025 is dismissed.
2. The decision issued on 15 May 2025 by the EFA Appeal Committee is confirmed.
3. (…).
4. (…).
5. All other and further motions or prayers for relief are dismissed.
Seat of arbitration: Lausanne, Switzerland
Date: 3 March 2026
THE COURT OF ARBITRATION FOR SPORT
Frans M. de Weger President of the Panel
Christoph Müller Laila El Shentenawi Arbitrator Arbitrator