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What Constitutes ‘Assault’ On Football Referees & How Is It Punished? (Curran v London County FA)

What Constitutes ‘Assault’ On Football Referees & How Is It Punished? (Curran v London County FA)
Thursday, 02 February 2023 By Mass Ndow-Njie

In a recent case before an FA Appeal Board (Miles Curran v London County FA), a Player sprayed a referee with water from a plastic bottle and then subsequently threw the same bottle at the referee. The Player was charged by the London FA with a breach of the FA Rules, rule E3.1 on the basis of:

  1. assault or attempted assault on Match Official, or alternatively

  2. improper conduct against a Match Official (including physical contact or attempted physical contact and threatening and/or abusive language/behaviour1.

This raised the following questions:

  1. What constitutes an ‘assault’ in sport?

  2. Where is the line to be drawn between an ‘assault’ and the lesser offence of ‘physical contact’?

The decision of the FA Appeal Board has provided some much-needed clarity addressing these questions insofar as they relate to offences against match officials in football as outlined in paragraph 96 of the FA Disciplinary Regulations, Part D – On-Field Regulations, Section 3 (“OFR, Section 3”)2.

The charge was first heard by an FA National Serious Case Panel which, sitting on behalf of the London FA, found the charge proven on the basis of assault or attempted assault pursuant to paragraph 96.3 of the OFR, Section 3. However, the FA Appeal Board overturned this decision and replaced it with a finding that the charge was proven on the lesser offence of ‘physical contact’3.

The Appeal Board’s decision is a welcome one which will assist the FA and Participants alike when they are considering charges relating to offences against Match Officials. However, while this case has shed light on how the FA will interpret an ‘assault’ in the OFR, Section 3, it is also key to understand the different approaches that are taken by the different organisations in football.

This article will explain the background to the case, the effects of the Appeal Board’s decision and compare the law on assaults in football applying from the grassroots level in England, to the highest levels of football in England, and all the way up to cup competitions organised by UEFA.

It examines:

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Written by

Mass Ndow-Njie

Mass Ndow-Njie

Mass is a UK-based barrister with a multi-disciplinary practice that includes sports law. During his pupillage, he was exposed to a range of sporting matters in cases where his supervisors were representing clients which included Premier League football clubs and a Formula One racing team. Mass has since been instructed as sole counsel in sports cases before various Football Association (‘FA’) panels, including the FA Serious Case Panel and the FA Appeal Board.

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