El Masry SC v. Eze Emeka Christian

Nigerian defensive midfielder Emeka Christian Eze played for Port Said club El Masry SC from 2018 to 2024. His contract conditioned the final 25% of his salary on having played in at least 75% of the season's matches. He claimed a final unpaid instalment of USD 70,968; the club relied on the participation clause, an alleged signed release form, and a limitation defence.

FIFA's DRC ruled in the player's favour (decision FPSD-18676, 25 April 2025). El Masry appealed to CAS, and a hearing was held on 13 October 2025 before Sole Arbitrator, assisted by CAS Counsel Amelia Moore. The club called its administrative manager, Soliman Elbihiry, as a witness, alongside legal counsel Walid Salah; the player was represented by Ignacio Triguero, Natalia Randa, and Hamza Abdelwahab.

On the disputed release form, the player argued its signature was substantially different from his signature on the employment contract and on his Nigerian passport. The Sole Arbitrator found that the contract signature and a genuine release form from the 2021/2022 season were visually consistent with each other and with the passport signature — and noted, as a further point going to the credibility of the club's position, that the passport itself had been issued on 23 August 2024, only three weeks before the disputed release form was allegedly signed. Given El Masry could not discharge its burden of proving the disputed signature was genuine against this consistent pattern of authentic exemplars, the Sole Arbitrator declined to even reach the separate question of whether the release form, had it been genuine, would have validly waived the outstanding amount at all.

CAS dismissed the appeal in full. The participation clause was held potestative, null and void — fielding decisions rest solely with the club, so a player cannot fairly be penalised for not playing enough matches. The claim was not time-barred, since the limitation period runs from each salary instalment's due date, not the date the contract was signed. El Masry was ordered to pay the full USD 70,968 plus 5% interest annually from 1 June 2024.