Pitch Invasion: Football League announce decision in Blackpool v Huddersfield Town

On 14 May 2015 the Football League announced that the abandoned match between Blackpool and Huddersfield Town on 2 May 2015 has been decided as a 0-0 draw – the score at the time the match was abandoned. Blackpool have been charged and referred to the Football Disciplinary Commission.

Thankfully, with under-soil heating, floodlights, pre-match pitch inspections, less fog, and calmer supporters (on the whole), professional matches in England don’t get abandoned like they used to.

However on 2 May, the match was abandoned after fans stormed the pitch in protest – something that was probably not at the forefront of Blackpool and Huddersfield Town minds before the final game of the season.

Blackpool had endured a disappointing season culminating in relegation to League One. Huddersfield Town were destined to finish mid-table, although a win would have seen them leapfrog West Yorkshire rivals Leeds United into 15th position.

The Blackpool fans were so unhappy with their team’s season (and owner) that 2,000 of them protested outside the ground before the match. So unhappy, that on 48 minutes, with the scores at 0-0, hundreds invaded the pitch. The referee had to abandon the match and get the players off the pitch for their own safety.

After the match, the Football League announced that there would be no replay of the fixture, and that it would hold a board meeting to decide the outcome.

While the difference in prize money between 15th and 16th place in the Sky Bet Championship is quite small compared to the money in football overall, the principle is important. What if the last match of the season, between 4th and 5th in the Premier League was abandoned when the teams were level on points? What if that match was just before an international break and no match could be rearranged? What if the home team was losing in the abandoned match and won a replayed match?

The potential consequences of abandonment are huge and it is important for clubs to know: what abandonment means; what the league can do in response; and what they can do if they feel the league gets it wrong?

A match is abandoned, what does it mean?

According to the current Laws of the Game (as authorised by FIFA and IFAB), the referee has the authority to abandon the match, at his/her discretion, for any infringement of the rules or because of any outside interference1.

The Football League matches, such as the Sky Bet Championship match between Blackpool and Huddersfield Town, are subject to the Laws of the Game. Therefore the referee was within his authority to abandon the match on 2 May.

If the match had been in the Premier League, the current Premier League Handbook provides guidance on other occasions when a Premier League match will be abandoned, which include: on the instructions of the Premier League Board; by order of the police; or by an authority exercising its statutory powers2.

What powers do the leagues have?

As you’d expect, an abandoned match doesn’t automatically result in the scoreline as it was when the match was abandoned. An abandoned match will be replayed unless the competition rules provide otherwise3.

We all know a football match lasts for 90 minutes, but where a match doesn’t last that long, the Football League Executive has full discretion to order a replay in full or in part (and on whatever conditions it decides), or for the match to count as a completed fixture4. Alternatively, if the Football League Executive was to find misconduct by the clubs, it may refer the matter to the Football Disciplinary Commission5.

The Football League released an official statement after the Blackpool v Huddersfield Town match, which said: “following the abandonment of today’s match…it will be for the FA to consider any matters relating to crowd behaviour with the Football League ruling on whether or not the match should be replayed”.

After deciding it should not be replayed, the Football League explained that it would decide the result at a Board meeting, which was held on 14 May 2015. The Football League Board eventually took the view that league points should always be earned on the field of play (and so the score was as at the time of abandonment). The Board has charged Blackpool with failing to fulfil a fixture and referred the charge to the Football Disciplinary Commission.

Looking at the Premier League, its powers are much the same. The Premier League Board may order a league match which lasts less than 90 minutes to be counted as a completed match or replayed. Causing a match to end before 90 minutes is a breach of the rules, and the disciplinary procedures provide that upon hearing the matter (and any mitigating factors) the disciplinary Commission may make such order as it sees fit6.

What happens if the leagues don’t get it right?

Any appeal against the Football League or Premier League will depend on whether there  is a finding of misconduct (ie that a club has breached the rules in causing the match to be abandoned), or whether the abandonment was outside of the clubs’ control. In the case of misconduct, the matter may be referred to the disciplinary commissions and subsequent decisions can be appealed by the clubs.

In practice, appeals against disciplinary decisions in the Football League can only be made if the decision was based on: incorrect information (and was obviously wrong); there was a serious irregularity in the conduct of the proceedings; or the order is too severe (or too lenient) in the circumstances7. A club cannot appeal simply because it disagrees with the outcome.

In the Premier League, the rules simply provide that a club can appeal against decisions of the Commission in circumstances where the club appeared before the Commission as a respondent8.

In the case of Blackpool v Huddersfield Town, should Huddersfield wish to challenge the decision of the Football League Board, it would need to mount a separate legal challenge through the courts. The courts are aware of the unrivalled and practical experience sports bodies have, and will not interfere with Premier League or Football League decisions unless they are contrary to the rules (or are contrary to general law)9.

Is the process the same beyond English football?

Each football association outside of England, and indeed for each sport outside football, is governed by different rules with regards to abandonment of matches.

Interestingly, if a FIFA World Cup 2014 match had been abandoned due to forces outside of the teams’ control, the FIFA Organising Committee would have retained sole discretion on deciding the outcome of the match10.

Meanwhile, the Rugby World Cup 2015 will adopt a strict approach to abandoned matches. Looking at the pool matches, where a match is abandoned before half time at the fault of neither side, the match is decided as a draw; this is regardless of the scoreline which is kept for the purposes of points difference. If it is abandoned at or after half time, the score will be the same as it was at the time of abandonment11.

Comment

When the teams walked out onto the pitch on 2 May 2015, they would not have been expecting what was to come. The bodies that regulate and control English football competitions retain a high level of discretion – in this instance, deciding to leave scores to be determined on the pitch. It is interesting to think whether the result would have been the same if the teams had been pushing for play-off places?