After another Calcutta Cup classic, we dive into a law discussion from a Six Nations epic that saw England narrowly beat Scotland 16-15 at Allianz Stadium, Twickenham.

The smallest of margins decide the tightest of Test matches and often it can be the momentum swings of debatable officiating calls.

While this may have been the case on Saturday evening in London, Scotland still had several opportunities to seal the win without the intervention of the whistle, while the same was true for England, who did emerge victorious.

The man with the whistle for the fixture was Frenchman Pierre Brousset, who made his Six Nations debut taking charge of his 13th international match. He was assisted on the day by Andrew Brace, Luc Ramos and TMO Tual Trainini with South Africa’s Quinton Immelman operating as the Foul Play Review Officer, though he was not called upon.

With just one point separating the two teams, we review five crucial decisions in the clash.

Tommy Freeman’s ghost try

Scotland took an early lead in the encounter with a belter of a try as Ben White scorched through the Red Rose defence to put his side 5-0 ahead as Finn Russell missed the ensuing conversion.

However, England quickly went about their reply and were given access to Scotland’s 22 when Jonny Gray, Duhan van der Merwe and Jack Dempsey failed to react to Brousset’s call of the tackle being completed as they dragged Tommy Freeman into touch and were rightly penalised.

England set-up a lineout some 10 metres out from the try line and went on the attack. 12 phases later, Freeman gets his hands on the ball as he charges towards the try-line but is met staunchly in defence by Pierre Schoeman, Tom Jordan and Russell who desperately attempt to stop the winger from scoring.

Crucially, referee Brousset adjudged that the winger had managed to ground the ball despite the best efforts of the Scottish defenders.

A 2022 World Rugby TMO Protocol update confirms that the officiating team may review the legality of a try once the conversion has been taken but this must be done before the next restart has occurred.

“Should the broadcaster provide an angle after a conversion takes place but before the restart has been taken, that clearly shows an infringement has taken place, then the TMO/referee should use the video referral process to deal with the infringement,” the update read.

A 2025 update further clarifies that the “time window for any process following a try is until the subsequent restart kick, not the conversion kick.”

TMO Trainini raised doubt around the grounding of the ball before Russell restarted with the kick-off after Brousset confidently made his decision and opted not to formally review the try. However, Trainini swiftly had a change of heart with the broadcasting commentators – who have access to the comms between the officials – stating that he ‘is now happy that the try was scored’.

It’s worth noting that while we as spectators did not see an angle clearly showing a grounding, the TMO is provided with multiple additional angles that are not always broadcast, one of which may well have confirmed the try had in fact been scored.

Speaking after the match, Freeman coyly addressed the try with a sheepish grin.

“The referee said I got it down, so he must have seen it on the ground. I felt like it went on the ground,” he said.

Freeman to his credit, is right. The referee is defined by World Rugby’s laws as ‘the sole judge of fact and of law during a match’. If he saw the ground and the TMO did not have ‘clear and obvious’ evidence to overrule his decision, then it remains. Brousset was confident in his decision and stuck by it and for a referee with such little experience, one has to respect that.

Maro Itoje turnover

Into the second half of the match and England captain Maro Itoje produced another moment that has proven to be hugely controversial.

Scotland launched an attack from a lineout just outside the England 22 with Russell throwing a dummy before sprinting into a gap. He gets dragged down a few metres short but England’s defence holds firm and repeatedly pushes the Scottish attack backwards until Blair Kinghorn is wrapped up by Elliot Daly and Itoje spots his opportunity to pounce – literally.

The England skipper goes over Russell, who had entered the breakdown, and is quite clearly off his feet when he gets his hands on the ball.

Maro Itoje's turnover against Scotland 2025 Six Nations

There are several laws to consider here, they are:

15.2: “A ruck is formed when at least one player from each team are in contact, on their feet and over the ball which is on the ground.”

15.5: “An arriving player must be on their feet and join from behind their offside line.”

15.11: “Once a ruck has formed, no player may handle the ball unless they were able to get their hands on the ball before the ruck formed and stay on their feet.”

15.12: “Players must endeavour to remain on their feet throughout the ruck.”

Itoje penalty vs Scotland
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With Russell entering the breakdown first and Itoje later, it means that a ruck has been formed as per law 15.2 which means that Itoje must be on his feet which is not the case and he may not handle the ball (15.11). He also fails in his endeavour to remain on his feet throughout the ruck (15.12).

Simply put, Russell was correct in his pleas to the official who explained to the Scottish co-captain that he judged Itoje to be the “first man” to the ball before and that a ruck “had not been formed” when he got his hands on the ball.

Last year Springboks head coach Rassie Erasmus, who has a chequered past with officials, expressed sympathy for referees who make “950 decisions or non-decisions” in a Test match and in this case, unfortunately for Brousset this is one that he got wrong.

However, it’s worth adding that the officials work as a team and Brousset’s assistant could have prompted the young referee of the incident.

TMO Referral for the tackle on Ollie Chessum

Soon after the Itoje turnover, another incident that has caused some debate amongst Scotland fans was the TMO’s intervention which resulted in a penalty reversal after Kyle Rowe’s high tackle on Ollie Chessum.

On the hour mark, flanker Jamie Ritchie pilfered over to win a penalty for Scotland with Russell attempting to find touch but the ball was kept in by Henry Slade who scuffed a clearance just outside his 22.

Scotland were set to have a lineout from the mark but the TMO intervened at this point to prompt Brousset about the dangerous tackle that occurred before Ritchie’s turnover.

After reviewing the incident, the referee deemed that it warranted just a penalty against Rowe as his tackle did not justify any further sanction. It was not that decision that irked some fans but the timing of the TMO’s call as many believed that it occurred too late and play should have continued.

However, the latest World Rugby TMO Protocol update published this year states that Foul play (Law 9): “Dangerous play where the outcome would only be a Penalty”, may be “reviewed at any stage of the game, since the last restart and before play restarts again.”

It adds for clarification: “For any of these offences: This includes up until the start of a lineout after a kick to touch from a penalty or free kick.

“Should a quick tap or quick throw take place, and the TMO is unable to come in before the tap/throw is taken, the TMO may come in at the next available opportunity.”

In regard to this particular decision, Planet Rugby sought the expertise of a current elite professional match official for clarification on whether TMO Trainini acted beyond the reach of his duties.

They confirmed that he was within his rights to interject with the TMO able to do so until the lineout starts – for matters of foul play – with this being in the protocol ‘for some time’ now.

From the ensuing penalty, England would kick to touch and a few phases later earn a penalty which Marcus Smith will slot to put the hosts ahead by three points with less than 15 minutes to play.

Rory Darge’s infringement

A decision that Scotland head coach Gregor Townsend was left perplexed by was the one that led to England extending their lead to six points.

His side attacked from a lineout with Matt Fagerson crashing the ball up before Rory Darge and Jordan lifted Ben Curry of his feet at the ruck and dumped the England player on the ground.

Brousset blasted his whistle before stating that Darge and Jordan had ‘released him in the air’.

England captain Itoje pleaded ‘that was foul play sir’ with the referee replying “It’s penalty because he lands on the back.”

He further explained to Russell that: “He cannot release the player when he is in the air, it is foul play, you have to bring him to the ground.

After the match, Townsend bemoaned that the Scotland players had not taken Curry beyond the horizontal though; “I did feel that the decision that counted against us for the winning three points, where we cleared someone out of the ruck, I just don’t know how that’s a penalty.

“We’ve moved someone off the ruck and they’re two feet off the ground and there was no moving legs above the horizontal. That was an interesting call for us to end up going six points behind.”

Frankly, Brousset had a few avenues to go down with this decision as in addition to dropping Curry, Darge also goes into the ruck from the side.

Rory Darge clearout against England during the 2025 Six Nations

Rory Darge clearout against England during the 2025 Six Nations

Law 15.5 states: “An arriving player must be on their feet and join from behind their offside line.”

Darge does not do that while he and Fagerson can be penalised simply under law 9.11 which states: “Players must not do anything that is reckless or dangerous to others including leading with the elbow or forearm, or jumping into, or over, a tackler.”

That particular law is quite broad and once the Scotland pair lifted Curry, they always ran the risk of transgressing it when they didn’t put the England flanker safely back on the ground.

For a long time now, if a tackler or in this case a player entering the ruck, lifts a player off their feet, they are required to bring them to the ground safely or be sanctioned. Townsend may have his complaints but quite simply it is a penalty – harsh or not – and a silly at that.

Russell kick placement

Many onlookers were left perplexed as to why Russell’s conversion attempt to win the game wider of the mark from the position that Duhan van der Merwe scored.

Footage has since emerged showing that Brousset had instructed the kicker to move the mark from where he initially set-up, which was the correct spot. This was in fact an error from the official and ultimately did make the kick marginally more difficult for the Scotsman who had already missed his previous two chances.

World Rugby Law 8.8.a states that the kicker: “Takes the kick in the field of play on a line through the place where the try was awarded, parallel to the touchlines.”

six nations duhan van der merwe try and finn russell kick.

six nations duhan van der merwe try and finn russell kick.

There has to be some sympathy for the referee though as kickers repeatedly chance their arm by attempting to move their tee closer or into a better position after the referee has given his mark.

It’s a common occurrence and considering the magnitude of the kick, Brousset felt that Russell was attempting to do just that. The Scotsman paying for the previous sins of his fellow kickers and perhaps some of his own.

Additionally, with World Rugby reducing the time limit for conversion from 90 seconds to 60, there is almost no time for the referee to converse with his TMO or assistants to ensure the placement is correct if it is not done immediately. The rationale for the change is for shorter stoppages in play during a match and unfortunately, this is one of the trade-offs to achieving that.

Again, kickers will often take a conversion from the incorrect position – by a metre or two sometimes more – but this one was particularly notable because of the high profile of an England v Scotland match, the weight the kick had on the final result and the fact that Russell missed it. Had the Scottish pivot slotted the kick, there would be far less debate around the placement of the conversion if any at all.

READ MORE: Why Finn Russell’s missed match-winner was taken from a more difficult angle

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