Sports Law Library
A working reference for case law, regulations and frequently asked questions across international and African sports law — built and maintained by Legalify Attorneys.
CAS Principle of the Month
Termination for Just Cause
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Under FIFA’s Regulations on the Status and Transfer of Players, either party to an employment contract — club or player — may terminate it unilaterally where the other side’s breach is serious enough to make continuing the relationship unreasonable. This is “just cause.” It is a high bar, not a convenience. What consistently qualifies, across CAS’s own case law, is a club falling seriously behind on salary after being given a fair opportunity to put things right.
In Al Zamalek Club v. Ibrahima Ndiaye (CAS 2025/A/11214), the Senegalese player terminated his contract after the club failed to pay his salary for almost a full year. CAS confirmed he had just cause, rejecting the argument that his silence meant he’d accepted a pay cut, and struck down a clause letting only the club terminate unilaterally.
Persistent non-payment is treated as serious breach almost automatically. A player’s silence is not acceptance, and a club-only termination clause is likely to be struck down, not enforced.
Unpaid salary is real, usable grounds to terminate — but send a formal written default notice first. Documenting the breach strengthens your position considerably.