Nigeria: The Dispute Resolution Provisions Under The Enabling Statute Governing The Nigeria Professional Football League – Is It Uhuru?

Last Updated: 7 December 2017
Article by Steve Austine Nwabueze

The League Management Company (LMC) in exercising its rights derived from the Nigeria Football Federation (NFF) Act 1990 as the sole regulatory authority for football in Nigeria, the NFF which is the owner of the Nigeria Professional Football League (NPFL) issued the license to organize and regulate the top tier league to the League Management Company (LMC) for the purpose of organizing and promoting the league to meet global technical and commercial standards1. It was also established to oversee the Professional Football leagues in Nigeria with a national membership organizational structure for professional football through which the LMC can facilitate financial success, stability and development of professional football clubs, administer and regulate the professional game and promote the ethos of arguably the world's most popular sport. In developing a blueprint therefore for the administration and organization of the round leather game, the LMC established some Rules geared towards an effective management of the league. By Section A, Article 1.4 of the 2016/2017 Framework & Rules of the LMC, the LMC is a private Limited Liability Company governed by the Companies & Allied Matters Act, 2004 and is therefore armed with all the powers of a private Company incidental to incorporation.

The Vision

The preamble to the 2016/2017 LMC Rules sets out the objective intended to be achieved by the body in the discharge of its duties. Very conspicuous amongst these Rules is the LMC's duty to ensure that Football Clubs discharge their financial responsibilities and obligations to each other and the players promptly and fully without seeking to avoid them. Interestingly, the LMC is saddled with the responsibility of resolving differences between each other without recourse to the law Courts. The Rules go on to make an elaborate dispute resolution provision which seeks expeditious disposal of cases before the disciplinary committee of the LMC. While this objective is laudable, it is fraught with its own peculiar problems and raises niggling posers like the issue of enforcement of the decisions of the disciplinary committee of the LMC. For the moment, it would suffice to examine in detail, the dispute resolution provisions of the LMC Rules.

The Dispute Resolution Provisions of the LMC Rules

The Dispute Resolution Provisions under the LMC Rules can be found in Section D of the Rules. Given the welter of labour-related issues ranging from non-payment of salaries and sundry packages between players and their teams, it is little wonder then that the Rules stipulate that all labour-related disputes with a club over unfulfilled contract agreement or conditions of service shall in the first instance be submitted to the Arbitration & Dispute resolution Committee2 . The petitioner however must have issued the mandatory 30 day pre-action notice to the club before initiating proceedings before the disciplinary Committee of the LMC. The 30 day notice to the club is ostensibly to enable the club and the aggrieved player explore in-house dispute resolution mechanisms to reach amicable settlement. It is only when the parties fail to reach a compromise on the dispute that the jurisdiction of the Committee is activated3.

By Article 4 of Section D of the Rules, the decisions of the Committee are final and binding on all parties concerned. Section E of the Rules provides for Appeals, Adoption & Enforcement. Thus, a party dis-satisfied with the verdict of the NFF Disciplinary Committee reserves the right to appeal to the NFF Appeals Committee; provided that where an appeal or election for hearing pursuant to a notice for hearing have been found to be frivolous, such party may be liable to such additional sanction as deemed fit in the circumstances. Every Appeal must indicate clearly and fully the grounds on which it is based and must be lodged in writing with the General Secretary of the NFF within 48 hours of receipt of the Disciplinary Committee4. A remarkable introduction to the Rules is the provision relating to the mandatory payment of the sum of N500, 000.00 (Five Hundred Thousand Naira) by the appellant for the prosecution of the appeal. Whilst this provision at first glance appears to be a deterrent against filing of frivolous appeals, it is clear that this provision could equally deter an appellant who has genuine and arguable grounds of appeal from proceeding with the matter. With the litigation window closed to such a party, the party's right to action may as well be considered dead.

The implications of this provision become clearer when we consider the peculiar situation of the Nigerian league where players and staff of Football clubs are owed salaries for months. An aggrieved player who initiated proceedings before the disciplinary committee of the NFF and lost out on a technicality would need money to prosecute the appeal. In the event that the subject of the dispute revolves around non-payment of salaries and the player cannot prosecute the appeal on the grounds of impecuniosity, what remedy is left to such a player? Having closed the window to litigation, such a player cannot for very obvious reasons, approach the National Industrial Court for a remedy. The ready wicket/proposition enthusiastically pursued by the proponents of the exclusion of the Courts from the resolution of disputes in sports is amongst others, the fact that it is time-consuming and expensive. It is however difficult to identify the 'pocket-friendliness' of this provision on dispute resolution.

Whilst the writer shares the widely accepted sentiments of deterring wily clubs or players from pursuing a frivolous appeal, a club desirous of frustrating the payment of genuine salary claims would be more than ready to pay the statutory fee reserved for the prosecution of appeals under the Rules. Then there is the issue of enforcement of the awards and Orders of the LMC. Does it have enough coercive powers to go after football clubs and persons brazenly flouting its awards and orders? To what extent can it have recourse to its coercive powers where a club is in contempt of an award duly made by the LMC and what is the maximum punishment for such behaviour? Perhaps one of the cases before the LMC illustrative of the helplessness of the LMC in this regard is the case of Coach Imama Amapakabo against his erstwhile employers, Rangers International Football Club of Enugu. Coach Imama was contracted by the Enugu-based club initially on a one year contract before the commencement of the 2015/2016 league season. Following the resounding success recorded by the club in breaking the 32 year old jinx of not winning the league title, Rangers were desperate to keep their Manager who unsurprisingly became the subject of lucrative offers from rival clubs. Imama's superior bargaining power ensured he got the better deal with Rangers which culminated in a lucrative but largely incentivized contract. Following the renewal of the contract between both parties, expectations were understandably high at the club especially regarding their qualification for the continental footballing showpiece, the CAF Champions League. Things however never went as planned as the club became enmeshed in crisis ranging from injuries to key players, lack of transfer activity and Management issues. Imama, expectedly, bore the brunt of the club's poor showing in both the Champions league and the domestic league and was sacked. However, facts made available to the public showed that Coach Imama had outstanding salaries and allowances due and unpaid by Rangers FC. Imama activated Section D of the LMC Rules by resorting to the dispute resolution platform of the LMC after issuing the mandatory 30-day pre-action notice, claiming wrongful dismissal and seeking compensation to the tune of N38 million.

That fee includes full payment for the remainder of the contract term, N2 million as two months' salary arrears, N600 000 in outstanding allowances and bonuses, $940 international travelling allowance and N16 million as damages for breach of contract.

In their defence, Rangers claimed that Amapakabo was fired for falling foul of the 'failure to perform' clause of his contract with the club.

However, the clause defines 'failure to perform' on the part of the coach as 'inability of the coach to impart football knowledge on the players or several defeats of the team due to his own fault'.

By contrast, the same clause defines 'failure to perform' on the part of the club as 'failure of management to provide adequate motivation including payment of allowances and salaries when due'.

Amapakabo argued that the defeats were not his own fault but that of the club in failing to pay players' wages which led to training boycotts and at least one instance of players refusing to travel for a continental game. Rangers' lawyers, in their defence, then proceeded to shoot themselves in the foot by admitting that while the club did owe players, 'it is not the only club that owe her players in Nigeria.'

The LMC ruled in favour of Amapakabo, finding that there was insufficient proof that he failed to perform, but more than enough -- and on the evidence of the Rangers lawyers' admission -- that the club failed to perform. "The Club wrongfully terminated the Contract of Service it entered into with the coach," was the LMC's decision. Rangers were directed to pay the coach his salary arrears, N600 000 in outstanding bonuses and allowances and $940 in international travelling allowances, but the LMC directed both parties to work out an amicable compensation settlement for the wrongful termination of contract. Rather than settle, however, Rangers had Amapakabo arrested on July 19, 2017 where he was detained overnight for being in possession of the club's properties. Imama had responded thus, "I have been humiliated and spent a night in police cell just for asking for what is my right. If the LMC do not do something about this, I will have to go to court."

In a swift response, to the incident, the LMC Chairman, Shehu Dikko responded thus; "This is unacceptable and capable of bringing the league to disrepute," Dikko, who was in Morocco for the CAF Symposium, told KweseESPN5, "but I cannot make any comment as yet until I have been fully briefed by the office."

The Enforcement Conundrum of the LMC Orders

It is not clear whether the LMC administered any further punishments on Rangers following this fiasco especially in view of the provisions of Article 7 Section D of the Rules which precludes resort to litigation as a dispute resolution option. Article 6 of Section D of the Rules empowers the LMC to withhold monies accruing to a defaulting club for the purpose of settling a judgment debt. It is difficult to imagine the category of funds accruing to a defaulting club that can potentially offset such debts nor whether such funds are substantial enough to settle such obligations. This becomes more evident when it is realized that a large chunk of the clubs' revenue comes from gate fees and sponsorship deals. How the LMC can get hold of such revenue accruing to the clubs beats the imagination. Interestingly, there is no maximum penalty stipulated in respect of such defaulting clubs. The Rules merely stipulate that the failure to comply with any decision of the Arbitration Committee "may" cause the club to be expelled from the league6. The operative word 'may' suggests that this is entirely discretionary. The only known case of outright expulsion from the Professional football league is that of Giwa FC of Jos who were expelled as a result of their unexplained boycott of three successive games in contravention of the LMC Rules7. The LMC is yet to wield the big stick in this regard in respect of clubs flouting their financial obligations. The writer wonders where the LMC would derive its coercive powers if not already provided for in its enabling statute.

The LMC strangely, has been very effective in exacting punishments on clubs for infraction of its Rules regarding control of the fans, assault of match officials and boycott of matches. Penalties ranging from N10, 000, 000, N5, 000, 000 etc. have been imposed and enforced against such clubs. Why then does the LMC appear powerless in regulating club-player relations?



2. See Section D, Art 1 of the LMC Rules

3. Section D, Art 3.

4. See Article 2, Section E of the LMC Rules.

5. Collin Udoh, Kwese.Espn, July 20, 2017

6. Article 5 of Section D of the LMC Rules, 2014

7. Vanguard Newpapers, May 19, 2016.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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