Warburton: Spear tackles Clerc

Warburton was shown a red card by referee Alain Rolland for lifting French wing Vincent Clerc horizontally in a tackle. The France star landed on his back with his feet in the air.

Law 10.4(j) reads: "Lifting a player from the ground and dropping or driving that player into the ground whilst that player's feet are still off the ground, such that the player's head and/or upper body come into contact with the ground, is dangerous play. Sanction: Penalty kick."

In 2007, the IRB council approved a law ruling which made it clear that lifting and tipping tackles constituted dangerous play.

A subsequent referees seminar in London agreed that officials should "start at red and work backwards" for those types of tackle.

In 2009, the IRB's referees' manager Paddy O'Brien issued a memorandum emphasising the need for dangerous tackles to be dealt with severely.

The memo listed three possible scenarios where the tackler is lifted horizontally off the ground:

:: The player is lifted and then forced or "speared" into the ground. A red card should be issued for this type of tackle.

:: The lifted player is dropped to the ground from a height with no regard to the player's safety. A red card should be issued for this type of tackle.

:: For all other types of dangerous lifting tackles, it may be considered a penalty or yellow card is sufficient.

Warburton insisted after the game that there had been no malicious intent, but the memo adds: "Referees and citing commissioners should not make their decisions based on what they consider was the intention of the offending player.

"Their decision should be based on an objective assessment of the circumstances of the tackle."

An IRB spokesman said: "Regular directives to unions, match officials and judicial officers have been issued in recent years reinforcing the IRB's zero-tolerance stance regarding dangerous tackles and the promotion of player welfare."