Kassoum v ECOWAS Commission (ECW/CCJ/APP/24/24; ECW/CCJ/JUD/46/25) [2025] ECOWASCJ 41 (19 November 2025)

Source-derived case information.

Citation: [2025] ECOWASCJ 41
Parties: Applicant: Mr. Kassoum Coulibaly Kassoum; Respondent: ECOWAS Commission
Court: ECOWAS Community Court of Justice
Jurisdiction: Ghana
Judgment Date: 19 November 2025
Case Number: ECW/CCJ/APP/24/24 ; ECW/CCJ/JUD/46/25
Procedural Posture: Employment/administrative / Final Judgment
Outcome: Application dismissed
Legal Topics: Conversion of Contract Staff to Permanent Staff, Secondment of Military Personnel, Exclusivity of Employment, Salary Suspension, Jurisdiction and Admissibility of Staff Disputes
Source Language: english

Employment Law International Administrative Law Conversion of Contract Staff to Permanent Staff Secondment of Military Personnel Exclusivity of Employment Salary Suspension Jurisdiction and Admissibility of Staff Disputes

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Parties

Mr. Kassoum Coulibaly Kassoum

Applicant

ECOWAS Commission

Respondent

Procedural Posture

Employment/administrative / Final Judgment

Legal Issues

1 Whether the requirement for resignation of military personnel prior to conversion to permanent ECOWAS employment is lawful
2 Whether the suspension of the Applicant's salary following his appointment as Minister in Burkina Faso was legally justified
3 Whether Burkinabe national law can ground conversion of employment status in ECOWAS

Ratio Decidendi

The requirement that military personnel resign from their national armed forces before conversion to permanent ECOWAS staff is a lawful and legitimate administrative measure to safeguard institutional integrity, neutrality, and exclusive loyalty, even if not expressly stated in the Treaty or Staff Regulations. The Council of Ministers' report is not a binding legal act and cannot ground a claim. The Applicant's reliance on Burkinabe law is misplaced as ECOWAS operates under its autonomous legal framework. The Applicant failed to prove entitlement to salary for the disputed period, having constructively abandoned his post by assuming ministerial office without authorization.

Court Disposition

Application dismissed

Orders

Application is admissible but dismissed on the merits
Applicant's claims on non-conversion and salary arrears are unsubstantiated and unjustified

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