Al-Hilal Club (Sudan) v. Lamin Jarjou & Grenoble Foot 38

Gambian player Lamin Jarjou left Sudanese club Al-Hilal after the Sudanese civil war broke out on 15 April 2023, when the Rapid Support Forces seized Khartoum International Airport, military installations, and the presidential palace. According to his own submission to CAS, he was evacuated via Egypt, Turkey, and Senegal back to his country of origin, Gambia, and Al-Hilal had by that point already failed to pay his salary for March, April, and May 2023, a debt his side quantified at USD 12,000 and gave the club a 15-day deadline to settle. He terminated his contract roughly two months after actually leaving the country, shortly before signing for French club Grenoble Foot 38 on a loan for the 2023/24 season, with Grenoble covering his full salary and holding a €250,000 purchase option.

Al-Hilal argued the delay between leaving Sudan and formally terminating undermined any force majeure claim, and separately challenged the admissibility of certain evidence Jarjou introduced only at the hearing stage. The panel accepted the new hearing evidence and found the timing gap did not defeat the claim: the essential basis of his employment — being able to actually live and train in the country where his club is based — had already been fundamentally and irreversibly altered by the outbreak of war, regardless of exactly when the formal termination letter followed.

The panel held the war constituted a genuine force majeure event giving Jarjou just cause to terminate, addressing directly a specific counter-argument Al-Hilal raised: that the war might not have made performance of the contract absolutely and finally impossible, since Al-Hilal itself had relocated abroad and resumed its own sporting activities despite the conflict. The Panel found this did not defeat Jarjou's claim, reasoning that the war was unexpected and of a magnitude not comparable to other disorders, that Al-Hilal itself had not anticipated the outbreak of civil war when the contract was concluded, and that a club managing to relocate and keep playing does not mean an individual player's own circumstances — his safety, his ability to live and train, and the wages he was actually owed — were unaffected. The appeal was dismissed, with Al-Hilal ordered to pay both Jarjou and Grenoble CHF 2,000 each — a significant precedent for how CAS treats war and civil conflict as grounds for termination even where a player does not act immediately upon leaving the country, and even where the employing club itself continues to operate elsewhere.