Article 14bis FIFA RSTP: CAS 2024/A/10777 Pharco SC v. Moses Turay

CAS 2024/A/10777 Pharco SC v. Moses Turay

Date of the decision: 2025-09-19

Arbitrator(s): Jamie Herbert

In the context of Article 14bis of the FIFA Regulations on the Status and Transfer of Players (RSTP), a default notice must precisely identify the alleged breaches to ensure clarity, legal certainty and contractual stability. If a player’s default notice is based on an incorrect allegation, the said player would not be able to rely on Article 14bis to terminate a contract. Nevertheless, pursuant to the FIFA Commentary on the RSTP, termination with just cause may still be found, even if all the formal conditions of Article 14bis are not strictly satisfied.

Facts and Procedure

On 25 July 2023, Moses Turay (the Player) and the Egyptian side of Pharco SC (the Club) concluded an employment contract (the Contract), valid until the end of the 2026-2027 season. Four versions of the Contract existed, identical except for a handwritten “additional provision” missing from the Player’s copy. The Contract integrated the Club’s internal financial and administrative regulations as part of its terms.

The Player was entitled to a total amount across four seasons, including a fixed amount for 2023-2024, with an initial instalment due on 30...

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