Professor Kwadwo Appiagyei-Atua of the University of Ghana School of Law has publicly argued that Gyamfi's recent remarks on unlicensed small-scale mining amount to an instruction to break the law.

According to Appiagyei-Atua, Gyamfi's formulation that anyone can mine as long as the site is not a water body, forest reserve, or roadside, pending registration, is not supported by Ghanaian law. Appiagyei-Atua grounds his argument in Section 9 of the Minerals and Mining Act, 2006 (Act 703), which bars anyone from mining without a mineral right.

He also cites Section 82, which requires a small-scale mining licence from the Minister or an authorised officer. The professor's central objection is to what he calls a reversal of the statutory scheme.

Gyamfi's comments have drawn criticism from the Coalition Against Galamsey and Minority MPs in Parliament, who have called for his dismissal. GoldBod has sought to contain the fallout, framing the controversy as a misunderstanding rather than a policy shift, according to Chale News.