Tonight sees the first of the play-off matches which will ultimately determine the final European representatives at the FIFA World Cup in Russia in 2018.  The fans of Northern Ireland, Switzerland, Croatia, Greece, Sweden, Italy, Denmark and the Republic of Ireland will all be excitedly following their teams’ progress, hoping that they are able to triumph over the course of the two-legged play-offs and to secure a place in Russia.

In terms of quality of football, the UEFA Champions League may now represent the pinnacle of the game to many fans.  Yet the FIFA World Cup unquestionably remains the highest level of international football.  It retains a certain glamour and provides fans across the world with one month every four years in which they can gorge themselves on a feast of football.

The World Cup also retains a position of importance for players.  Most (if not all) players grew up watching World Cups as youngsters and they still dream of the day that they represent their nation at the apex of international football.  Moreover, as the tournament comes around only every four years, a number of the world’s most talented players will never make it to a World Cup.  This is not a problem that the most gifted players tend to encounter in domestic football: the very best players tend to get a chance to play in UEFA competition at some point in their careers, as the best clubs will seek to sign them.  Yet international football often results in cases where certain players have the requisite skill-set to play at the World Cup but, put simply, their compatriots do not.  As a result, once qualification for a World Cup becomes a reality, players tend to give their very best efforts to secure a place at the tournament.

It is against this background that we consider the curious case of Greek defender Kostas Manolas.

On 7 November 2017, FIFA announced the latest disciplinary sanctions imposed for incidents that occurred during the last round of FIFA World Cup qualifying matches.  As part of such announcement, it confirmed that it had suspended Kostas Manolas from playing in Greece’s first play-off match against Croatia for trying to manipulate his disciplinary record.

FIFA is reported to have said that Manolas was guilty of “intentionally seeking a yellow card” for time wasting in the 90th minute of Greece’s 2-1 win against Cyprus on 7 October 2017.  The yellow card received by Manolas meant that he would be suspended for Greece’s match against Gibraltar three days later, which Greece went on to win 4-0.

The practical consequence of Manolas’s conduct was that he was able to use up his suspension before the important World Cup qualifying matches against Croatia.  Instead, he would miss only the match against Gibraltar (who are currently ranked 206th in the world), which Greece were expected to (and indeed did) win easily.  With respect to Gibraltar, Manolas presumably figured that he would be of more use to his team against Croatia than he would against Team 54.

Yet Manolas’s conduct did not escape the attention of FIFA, who imposed on him a one match ban pursuant to Article 57 of the FIFA Disciplinary CodeArticle 57 states that:

“Anyone who insults someone in any way, especially by using offensive gestures or language, or who violates the principles of fair play or whose behaviour is unsporting in any other way may be subject to sanctions in accordance with art. 10 ff.”

Article 57 is sufficiently broad as to encompass any conduct that “violates the principles of fair play” or any behaviour that is “unsporting in any other way”.  It is hard to argue that Manolas’s behaviour is not unsporting or that it does not violate the principles of fair play, particularly in circumstances where such notions are not defined in the FIFA Disciplinary Code (or indeed anywhere else).  Where the notions are not defined, it lies with FIFA to exercise its discretion and, in its view, Manolas’s conduct was unacceptable.

It is not however the first time that this sort of behaviour has been the focus of attention.  In 2004, David Beckham admitted that he had deliberately fouled Ben Thatcher in a match between England and Wales in order that he could pick up his second caution of the qualifying campaign and be suspended for England’s next match against Azerbaijan.  Beckham said that he knew that he would miss the Azerbaijan game through injury as he had already hurt his ribs in an earlier challenge with Thatcher.

At the time, Beckham’s confession caused a significant media stir.  While there was some reported talk of FIFA investigating, Beckham’s apology appeared to smooth things over and no action was taken (either by FIFA or by the FA).  Yet Beckham’s conduct appeared to receive some sympathy amongst his professional peers.  Former England defender Lee Dixon was quoted as stating that:

“A few people might raise an eyebrow as it has never been admitted to before.  But that sort of thing has been going on for years in football.  It’s not cheating – it’s just common sense….It’s a form of professionalism and as a professional footballer at the highest level you do push the limits of the law right to the edge.”

A BBC vote at the time found that 61% of those polled considered that Beckham had erred in telling people what he did, rather than in performing the act itself (only 19% considered the conduct to be Beckham’s error, while 20% stated that they thought he had done nothing at all wrong).

Clearly FIFA now considers behaviour of this nature to be contrary to the spirit of the game, as Manolas’s ban demonstrates.  Manolas’s suspension will mean he misses the first leg of the World Cup play-offs against Croatia.  He will however be able to play in the second leg.  Manolas and his countrymen will no doubt be hoping that his apparent error in judgement does not cost Greece dearly and that the Galanolefki do enough against Croatia to qualify for a place in Russia regardless.  The whole of Greece (and Croatia) will be watching closely.