Labour Disputes
Texto da decisão
REF. FPSD-19648
Decision of the
Dispute Resolution Chamber
passed on 4 February 2026
regarding an employment-related dispute concerning the player Zakariyya
Suleiman
BY:
Iñigo RIESTRA, Mexico
CLAIMANT:
Zakariyya Suleiman, Nigeria
Represented by Chijioke Okpanku
RESPONDENT:
Al Nwares, Libya
Represented by Muah Tashani
pg. 2
REF. FPSD-19648
I. Facts of the case
1.
On 1 December 2024, the Nigerian player Zakariyya Suleiman (hereinafter: the Player or the
Claimant) and the Libyan club Al Nwares (hereinafter: the Club or the Respondent) entered
into an employment contract (hereinafter: the Contract), valid for the 2024/25 season,
namely, until 30 June 2025.
2.
Clauses 1 and 2 of the Contract provided as follows (quoted verbatim):
“Article (1)
The first party [the Club] shall pay an amount of 1000 dollars to the second party [the
Player] in exchange for the latter party playing with the first football team of Al-Nawras
Club for the 2024/2025 sports season in all league and cup competitions.
Article (2)
The amount shall be divided into three installments as follows: The first installment is
25.00 dollars, the second installment is ........ dollars, and it will be between the first and
second legs, and the third installment is 1,500 dollars after the end of the sports
season.”
3.
On 6 June 2025, the Player and the Club entered into a mutual termination agreement
(hereinafter: the Termination Agreement), by which the parties released each other from all
legal consequences arising and resulting from the termination of the Contract.
4.
On 7 June 2025, the Player sent a formal notice to the email address
“[email protected]”, requesting the payment of USD 3,800 to be made within the next
10 days.
II. Proceedings before FIFA
5.
On 18 June 2025, the Player filed the claim at hand before FIFA. A summary of the parties’
respective positions is detailed below.
a. Position of the Player
6.
In his claim, the Player submitted that, in accordance with the Contract, the Club undertook
to pay him USD 4,000, payable in two instalments, as follows: USD 2,500 on an unspecified
date and USD 1,500 after the end of the sporting season.
7.
The Player further contained that the Club only paid him the amount of USD 200.
pg. 3
REF. FPSD-19648
8.
The Player alleged that, notwithstanding the signature of the Termination Agreement, the
Club still owes him the amount of USD 3,800 under the Contract.
9.
The Player requested the following relief (quoted verbatim):
“24. The Claimant respectfully urges the DRC to award the Claimant the underlisted reliefs
in the present dispute: The breakdown of the Claimant’s relief is as follows:
- The sum of $3,800 (Three Thousand Eight Hundred United States Dollars) which is the
salary of the 2024/2025 season.”
b. Position of the Club
10. In its reply, the Club alleged that it had not received any default notice from the Player.
11. The Club requested that the claim be dismissed on the basis that the parties had mutually
terminated the Contract and released each other from all legal consequences, in
accordance with the Termination Agreement
pg. 4
REF. FPSD-19648
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
12. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether he was competent to deal with the case at hand. In this respect, he took
note that the present matter was presented to FIFA on 18 June 2025 and submitted for
decision on 4 February 2026. Taking into account the wording of arts. 32 and 35 of the
January 2026 edition of the Procedural Rules Governing the Football Tribunal (hereinafter:
the Procedural Rules), the aforementioned edition of the Procedural Rules is applicable to
the matter at hand.
13. Furthermore, the Single Judge referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Nigerian player and a Libyan club.
14. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, he confirmed that, in accordance with art. 29 of
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
15. The Single Judge recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which he may
consider evidence not filed by the parties, including without limitation the evidence
generated by or within the Transfer Matching System (hereinafter: the TMS).
c. Merits of the dispute
16. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Single Judge emphasised that in the following
considerations he will refer only to the facts, arguments and documentary evidence, which
he considered pertinent for assessing the matter at hand.
pg. 5
REF. FPSD-19648
i. Main legal discussion and considerations
17. The Single Judge then moved to the substance of the matter and noted that the parties
were in dispute as to whether any remuneration remained outstanding under the Contract.
18. In particular, the Single Judge took note that the Player asserted that, notwithstanding the
execution of a Termination Agreement, the Club breached its contractual obligations by
failing to pay an amount of USD 3,800 due under the Contract.
19. The Single Judge was also observant that the Club contended that, by means of the
Termination Agreement, the parties had mutually released each other from any legal
consequences deriving from their contractual relationship.
20. In this context, the Single Judge acknowledged that his task was to determine whether the
Player is entitled to receive any outstanding remuneration from the Club on the basis of
the Contract.
21. As a preliminary consideration, the Single Judge noted that the Player claimed that, under
the Contract, the Club was bound to pay him a total remuneration of USD 4,000. In this
respect, the Single Judge recalled that the Contract contained, inter alia, the following
provisions (quoted verbatim):
“Article (1)
The first party shall pay an amount of 1000 dollars to the second party in exchange for
the latter party playing with the first football team of Al-Nawras Club for the 2024/2025
sports season in all league and cup competitions.
Article (2)
The amount shall be divided into three installments as follows: The first installment is
25.00 dollars, the second installment is ........ dollars, and it will be between the first and
second legs, and the third installment is 1,500 dollars after the end of the sports season.”
22. The Single Judge further noted that the Club had not contested the Player’s allegation that
the remuneration agreed upon under the Contract amounted to USD 4,000.
23. Furthermore, the Single Judge took into account that the numerical amounts indicated in
the original Arabic version of the Contract corresponded to the amounts claimed by the
Player, namely, USD 2,500 corresponding to the first instalment and USD 1,500
corresponding to the second instalment.
24. In view of the foregoing, the Single Judge confirmed that, pursuant to the Contract, the Club
undertook to pay the Player a total amount of USD 4,000.
pg. 6
REF. FPSD-19648
25. The Single Judge subsequently observed that, out of the total contractual total amount of
USD 4,000, the Player maintained that he had received only USD 200.
26. In this regard, the Single Judge observed that the Club failed to provide any documentary
evidence demonstrating that it had paid the remuneration due under the Contract.
27. Additionally, the Single Judge considered that the Termination Agreement did not provide
that all outstanding amounts under the Contract had been settled, nor did it contain any
explicit waiver by the Player of his right to claim outstanding remuneration arising from the
Contract.
28. In addition, the Single Judge further noted that the final instalment of USD 1,500 was
contractually due only after the end of the season, namely, as from 30 June 2025.
29. In this regard, the Single Judge also noted that the parties signed the Termination
Agreement on 6 June 2025, namely, prior to the date on which the obligation to pay the
aforementioned amount of USD 1,500 had fallen due.
30. In light of the above, the Single Judge established that, at the time of the termination of the
Contract, an amount of USD 2,300 remained outstanding, corresponding to the first
instalment of USD 2,500, minus the amount of USD 200 received by the Player.
31. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Single Judge decided that the Club is liable to pay to the Player the outstanding
remuneration in the amount of USD 2,300.
ii. Art. 12bis of the Regulations
32. The Single Judge then referred to art. 12bis par. 2 of the Regulations, which stipulates that
any club found to have delayed a due payment for more than 30 days without a prima facie
contractual basis may be sanctioned, in accordance with art. 12bis par. 4 of the Regulations.
33. To this end, the Single Judge noted that the Player sent a default notice of the amounts
sought, which had fallen due for more than 30 days, granting at least 10 days to cure such
breach of contract.
34. However, the Single Judge also noted that the Player had addressed his default notice to
the email address “[email protected]”, and that, according to the information
retrieved from TMS, said email address did not belong to the Club, but to the Libyan
Football Federation.
pg. 7
REF. FPSD-19648
35. Consequently, the Single Judge deemed that the Player had not properly notified the Club
in accordance with the requirements set out in art. 12bis of the Regulations. As a result,
the Single Judge decided that no sanctions could be imposed on the Club in the present
matter.
iii. Compliance with monetary decisions
36. Finally, taking into account the applicable Regulations, the Single Judge referred to art. 24
par. 1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA
deciding body shall also rule on the consequences deriving from the failure of the
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
37. In this regard, the Single Judge highlighted that, against clubs, the consequence of the
failure to pay the relevant amounts in due time shall consist of a ban from registering any
new players, either nationally or internationally, up until the due amounts are paid. The
overall maximum duration of the registration ban shall be of up to three entire and
consecutive registration periods.
38. Therefore, bearing in mind the above, the Single Judge decided that the Club must pay the
full amount due (including all applicable interest) to the Player within 45 days of notification
of the decision, failing which, at the request of the Player, a ban from registering any new
players, either nationally or internationally, for the maximum duration of three entire and
consecutive registration periods shall become immediately effective on the Club in
accordance with art. 24 par. 2, 4, and 7 of the Regulations.
39. The Club shall make full payment (including all applicable interest) to the bank account
provided by the Player in the Bank Account Registration Form, which is attached to the
present decision.
40. The Single Judge recalled that the above-mentioned ban will be lifted immediately and prior
to its complete serving upon payment of the due amounts, in accordance with art. 24 par.
8 of the Regulations.
d. Costs
41. The Single Judge referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Single Judge decided that no procedural costs were to be
imposed on the parties.
pg. 8
REF. FPSD-19648
42. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
43. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 9
REF. FPSD-19648
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Zakariyya Suleiman, is partially accepted.
2.
The Respondent, Al Nwares, must pay to the Claimant the following amount(s):
- USD 2,300 as outstanding remuneration.
3.
Any further claims of the Claimant are rejected.
4.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
5.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid. The maximum duration of the ban shall
be of up to three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
in the event that full payment (including all applicable interest) is still not made by the
end of the three entire and consecutive registration periods.
6.
The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 10
REF. FPSD-19648
NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 11