“Throwing” down the gauntlet: What constitutes an illegal delivery in cricket?

Published 25 May 2016 By: Anujaya Krishna

“Throwing” down the gauntlet: What constitutes an illegal delivery in cricket?

The issue of legality of bowling actions in cricket came to the fore again during the recent ICC World Twenty 20 tournament in India. Two frontline bowlers for Bangladesh - Taskin Ahmed and Arafat Sunny - were suspended after their bowling actions were deemed illegal.1 This followed the suspension and subsequent reinstatement of West Indies off-spinner Sunil Narine for suspect deliveries bowled during the third One Day International against Sri Lanka on 7 November 2015 in Pallekele.2

In light of these recent controversies, this article examines the Laws of Cricket3 (“Laws”) and ICC Regulations for the Review of Bowlers reported with Suspected Illegal Bowling Actions to explain exactly what does and does not constitute a fair delivery in cricket, and how the review and assessment procedure operates. 


The Laws of Cricket

The rules on what constitutes a fair delivery have changed over time. In 1816, the Laws stated, “the ball must be delivered underhand…with the hand below the elbow.”4 In 1806, Kent player John Willes is said to have been the first to bowl the “round arm” delivery at Lord’s, “using a sort of low slinging motion.” The Marylebone Cricket Club (MCC) called such an action “throwing” and initially tried to outlaw it. However, the popularity of round-arm bowling won through and it was legalized in 1835.5 

While taking their inspiration from Willes, today’s bowling actions have developed significantly, as have the Laws governing their legality. The MCC is recognized as the sole authority for drafting the Laws, and has been since its formation in 1787.6 When amending the Laws, the MCC consults the game’s stakeholders, including all the Full Member Countries of the International Cricket Council (ICC), which is the global governing body for cricket.7

The relevant Law governing bowling actions is Law 24 (No Ball). Law 24.2 sets out what is a “Fair Delivery” in respect of the arm (the feet are dealt with under Law 24.5). The Law simply states that,

For a delivery to be fair in respect of the arm the ball must not be thrown. See [Law 24.3] below

Law 24.3 “Definition of Fair Delivery – the arm” continues to state,

A ball is fairly delivered in respect of the arm if, once the bowler’s arm has reached the level of the shoulder in the delivery swing, the elbow joint is not straightened partially or completely from that point until the ball has left the hand.”8

Law 24 has been adopted in the playing conditions of the three most popular formats of the game:

The Law does not restrict a bowler from flexing or rotating the wrist in the delivery swing. Rather, it was designed to ensure that the bowler did not gain an unfair advantage by “throwing” the ball (or “chucking” it, in informal terms), because an elbow extension while delivering the ball may impart extra speed to the delivery.9

However, the Law has proved somewhat controversial. The ICC soon realized that, due to various physiological reasons, most bowlers’ arms straightened to different degrees when delivering the ball. Accordingly, if the Law – which requires “the elbow joint not [to be] straightened partially or completely” – was operated strictly, a significant number bowling actions would be deemed “illegal”.

As a result, the ICC amended the rule by permitting acceptable ranges of elbow extension (or “flex”) depending upon the bowler’s delivery type:

  • 10 degrees for fast bowlers,
  • 7.5 degrees for medium-pacers, and
  • 5 degrees for spinners.10

The amended test did not last for long though. Its limitations were highlighted in the relatively well know case of Sri Lankan player, Muttiah Muralitharan.11 Muralitharan was called for “throwing” several times. Biomechanical laboratory tests were conducted in Australia and the degree of flex in his arm was measured at around 10 degrees. Muralitharan argued that while spinners were allowed only 5 degrees of flex, his action should be legal because it should be the speed of the arm that determined the permitted degree of flex, and not the speed of the delivery. He stated that his “arm speed is fast as a fast bowler” and the tests confirmed it.12 What appeared to be an “illegal” action to the naked eye was in fact “legal”.

Further refinement was needed. In 2004, the ICC Cricket Committee constituted a panel comprising of Angus Fraser, Aravinda de Silva, Dave Richardson, Michael Holding, Sunil Gavaskar, Tim May and Tony Lewis to review and amend the test to make it more uniform. After consideration, the panel recommended a maximum of 15 degrees of flex to be allowed no matter what the style of the bowler. The 15-degree limit was chosen because, according to panel member Fraser, “that is the number which biomechanics says that it (straightening) becomes visible.”13 The rule was approved and came into effect from March 1, 2005.14


The ICC Regulations for the Review of Bowlers reported with Suspected Illegal Bowling Actions 

Today, the 15-degree limit is set out in the ICC Regulations for the Review of Bowlers reported with Suspected Illegal Bowling Actions (the “Bowling Regulations15), which detail the process for dealing with players suspected of bowling with an illegal action in all forms of international cricket. Section 6 of Annexure 1 states:

Acceptable Level of Elbow Extension

This should be set at a maximum of 15 degrees ‘Elbow extension’ for all bowlers and types of deliveries. This specifically refers to extension of the forearm relative to the upper arm to the straight position. Elbow hyperextension or adduction is not included in the 15-degree tolerance threshold. It should be noted that in order for the action to be classified as a legal action, the degree of ‘elbow extension’ recorded for each delivery should be within the 15 degree limit.

Procedure to review suspected illegal actions

Section 2 of the Bowling Regulations set out the reporting and analysis procedure for suspected illegal action in Tests, One-Day And Twenty20 Internationals. In brief, they require a Match Officials’ Report on the suspected illegal action to be sent to the Player’s team manager and the ICC within 24 hours of the match in which the suspect action occurred.16

The ICC then informs the player’s Home Board of the matter and “as soon as reasonably possible, and unless exceptional circumstances exist”, the player must undergo an Independent Assessment within 14 days (within 7 days in case of World Cup/Champions Trophy) of such intimation, to determine the legality of his bowling action.17

The player can continue to play if his action is found to be legal; but, if the result is to the contrary, he is immediately suspended from playing international cricket.18 However, if it is found that he employed an illegal action with respect to a specific type of delivery, other than his stock delivery,19 he is allowed to continue playing as long as he does not bowl the “illegal” delivery again.20

Recourses available to a suspended player

There are two avenues open to a player who has been suspended from international cricket for having an illegal action:

  1. work on his bowling action to remedy it and then apply for a re-assessment;21 or
  2. appeal to the Judicial Commissioner against the procedure followed by the ICC, leading up to and during the Independent Assessment.22

No appeal can be made against the scientific findings of the Independent Assessment; only procedural violations may be questioned. The ICC General Counsel appoints the Judicial Commissioner from among members of the ICC Code of Conduct Commission.23 Previously, the appeal used to be made to a Bowling Review Group (BRG) of the ICC, which had more members on board to decide on a case.24

A player can also inform the specialist conducting the Independent Assessment about any medical and/or scientific information relevant for the assessment. When Saeed Ajmal’s action was called into question, he cited medical grounds25 because there was a natural bend in his elbow and the ICC had cleared his action before in 2009. Ajmal finally had to remodel his action,26 before returning to international cricket in 2015.



Interestingly, with the change in the laws and new thresholds of testing, there has been a gradual (yet commendable) move away from a naming-and-shaming process, towards a more reformatory paradigm. Calling a player for “throwing” during a match tarnished many a player’s image and ended careers prematurely - for example, Australian cricketer, Ian Meckiff.27 Umpires who identified these bowlers also had their own share of trouble. Ross Emerson and Darrell Hair’s international umpiring careers were arguably shortened after their calling of Muralitharan for “no-balling” snowballed into controversy.28 Such incidents also leave a deep impact on the team the player belongs to,29 not only because their number of bowling options is reduced but also because of the moral implications of a teammate’s suspension for “unfair” play. The move toward an address and reform approach has to be positive.

However, the current system is not without its flaws. For example, it has been alleged that the procedure for reporting and testing suspect actions has not been rigorously followed in certain cases - take for instance the recent case of Bangladesh bowler Taskin Ahmed.30 Also, junior cricketers are not always fully aware of the rules on what constitutes a "fair delivery". Rather, the rules and procedures can be suddenly enforced on them at a professional level, when it is difficult for them to understand the problem and (more importantly) to amend their bowling action. 

There may also be issues around accessibility to legal recourse should a player wish to challenge a decision. For example, very few cricketers have taken recourse to the Court of Arbitration for Sport (CAS) due to lack of guidance and/or funds. And this point is particularly important as it is evident that the rules surrounding what constitutes a "fair" delivery in cricket are constantly evolving. Even now, there are studies that doubt the cause-and-effect relationship between elbow extension and increase in speed, which – if correct – means that in many cases the "flex" resulting from the bowling action might not be unfair to the sport after all.31

In light of these points, the author makes the following suggestions as regards the current rules and processes on illegal bowling actions:

  • The ICC, in consultation with stakeholders, needs to continue to strengthen and refine the infrastructure of detection and testing of suspect actions;32
  • More in-depth studies regarding the relationship between body mechanics and bowling actions are required. This will help prevent bowlers from being subjected to "suspect" action tests when it may be part of their natural action;
  • When determining legality of bowling actions other factors should be considered, such as the speed of the extension;
  • Awareness of the intricacies of the rules pertaining to bowling actions should be taught at the grassroots level, so that junior cricketers understand what an “illegal” action is and have the opportunity to correct it at a young age;
  • The ICC and Home Boards should facilitate players’ appeals against unjust suspensions to the CAS;
  • Technology should be used to assess legality of bowling actions during the match itself because asking a player to replicate the “suspect” action in a laboratory later cannot ensure 100% accuracy.33
  • As a general point, workshops should be established to promote integrity in cricket and help explain the rationale behind the Laws of the game. This will help to alleviate any sense of disgruntlement; for example among those who feel that cricketing laws are increasingly favouring batsmen;34

All in all, while trying to formulate solutions to the problem of illegal bowling actions, it must be remembered that cricket is a sport first and its essence as an art should be preserved, rather than over regulating it with arbitrary mathematical limits.


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Anujaya Krishna

Anujaya Krishna

Anujaya Krishna is currently working as a legal practitioner and legal knowledge consultant in India. She has been associated with the Sports Law team at Duane Morris and Selvam LLP, Singapore. She has authored a book entitled Sports Law and most recently got published in the Handbook on Sports Law. She has been keenly interested in Sports Law since her college days, and has several publications to her credit, in national journals as well as in international ones, such as the journal of the International Association of Sports Law, Greece.

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