Case Number:

ON/1121/25

Liam Horne #9, Castleford

Competition:

Super League

Match:

Castleford Tigers v Wigan Warriors

Match Date:

2025-06-28

Incident:

Contact with player who is or maybe injured

Decision:

Charge

Charge Detail:

Law 15.1 (i)

Makes unnecessary contact with a Player who is or may
be injured.

Grade E

Sanctions:

6+

Decision On Charge

Player plea:

Not Guilty

Summary of CM's submissions on the Charge / evidence:

Following a Match Review Panel meeting held on 30th June, you are charged with misconduct for a breach of Law 15.1(i) during the above match.

The Panel reviewed an incident which occurred at 01 53 26 footage time of the above match. In the Panel’s opinion you have unnecessarily lifted a player who appeared to be injured. In the Panel’s opinion this is serious misconduct, has the potential for serious injury and is against the spirit of the game.

In accordance with the RFL’s On Field Sentencing Guidelines, the Panel consider that such offence is a Grade E offence – Makes unnecessary contact with a Player who is or may be injured.

The normal suspension range for such offence is 36 Penalty Points (6 Match Suspension).

• The Match Review Panel reviewed an incident which occurred in the above match which was not subject to any refereeing action.
• After the tackle was complete; Mr Liam Horne aggressively pulled his opponent Mr Ellis shirt upwards forcefully enough that moved Mr Ellis along the ground.
• Mr Ellis at this point had not regained his feet. It is the actions of Mr Horne that are clearly moving Mr Ellis and not of the opponent’s own volition. Subsequently, Mr Ellis goes back down to the ground following the release of his shirt.
• It is not for any player in any circumstances to have physical contact with a player who may be injured. Injured players need treatment from appropriately trained medical staff to ensure that any injury is appropriately managed in the initial stages and is not made worse.
• Whether a player is in fact injured, and if so to what extent, is exclusively a matter for the assessment of the medical staff in conjunction with any necessary match official input. Contact, of whatever type/force, from another player upon a seemingly injured player has the potential for serious medical consequences for that injured player.
• In very limited circumstances a player may render immediate physical assistance to another player who is obviously seriously injured. This is not the case here. Mr Liam Horne is in no way attempting to assist the injured player. His actions are in a purely negative manner and for his own personal gain.
• The RFL stance on such situations is clear and a well-established precedent was set in 2021 and upheld by the ORT on various occasions. Hakim Miloudi of Barrow Raiders and Tendai Gwaze of Halifax Panthers received 8 match suspensions having been charged with Grade F (the grading has since changed) charges for moving an injured player. 2023 saw a specific charge brought in to further eradicate this unnecessary and dangerous action from the game.
• Clubs have been sent various notes on not to do this, and players have attended MRP training sessions in the past, with the message being specially raised that this is prohibited.

• This offence carries a strict Grading of E. The Match Review Panel submit that this matter should be dealt with via 36 Penalty Points which equates to a 6 Match suspension.

Summary of Player's submissions on the Charge / evidence:

Player in attendance alongside Danny McGuire (Head Coach) & Chris Chester (Director of Rugby). Player pleads not guilty.

CC questioned the grading of the offence, arguing that LH’s actions were not aggressive. He provided a definition of “aggressively” and argued that LS’s actions did not meet this definition.

CC presented evidence, including the Referee audio, which indicated that the opponent was not injured during the tackle. He added the club felt the opponent was time wasting and this was highlighted by the footage which showed the Referee’s instructions and the slow play by the Wigan players.

LH explained that he pulled the opponent by the shirt because he believed he was time wasting and not injured. This was indicated by the opponent’s laughter and smirk.

LH emphasised that there was no malicious intent in his actions and that he was not trying to injure the opponent.

LH then answered questions from the Compliance Manager. When asked what was required from him once a tackle was complete, he replied that he should step away and not be in contact with the opponent.

When asked how he knew that the opponent was not injured, LH said his laughter and smirk indicated he was not injured. The CM then asked about LH’s qualifications to assess injuries, LH responded by saying he knew the opponent and believed he wouldn’t be laughing if he was injured.

Decision:

Guilty

Reasons for Decision:

LH admitted to grabbing the opponent, stating that he knew the player was not injured and was smiling. Despite this, the contact was considered significant and against regulations.

The Chair emphasised that the contact was significant and in contravention of the regulations (laws of the game), which state there should be no contact. The grabbing of the shirt was not considered trifling or minor.

The Tribunal therefore find LH guilty of unnecessary contact, applying a high standard of proof based on the footage and admissions.

Decision On Sanction (where found to have committed Misconduct)

Summary of CM's submissions on the appropriate sanction:

The Compliance Manager reiterated his earlier comments that the sentence should start at a minimum of six matches (36 penalty points), whilst also taking into account any previous record the player may have.

Summary of Player's submissions on the appropriate sanction:

CC argued that incidents should be judged individually, considering the duty of care to both the player and LH. He emphasised the minor nature of the contact and potential impact on LH’s mental state.

Aggravating Factors:

26/05/25 – Trips – Intentional Trips – 3 penalty points

Reasons for Decision:

The Chair explained that the regulations dictate a minimum penalty for this offence which is 36 penalty points (6 matches). This is a mandatory requirement and there is no discretion allowed in the matter.

Despite acknowledging that the opponent was not injured and there was no malice involved, the Chair emphasised that the regulations still require the minimum penalty to be applied.

The panel note the previous record of the player. They have decided to order the 36 penalty points to run concurrently with that. This results in a six-match suspension. the player will also receive the standard fine.

Suspension:

6 matches