Pushing an elbow out is as bad as lifting it up. And since when is a “forearm shiver” a proper check? Any extended elbow is a penalty under the rules. And under the rules it doesn’t matter if there’s head or shoulder contacted first, as long as there’s injury to the head, it’s a major.
“Elbowing
Elbowing shall mean the use of an extended elbow in a manner that may or may not cause injury.
Minor Penalty - The Referee, at his discretion, may assess a minor penalty, based on the degree of violence, to a player guilty of elbowing an opponent.
Major Penalty - A major penalty, at the discretion of the Referee, shall be imposed on any player who uses his elbow to foul an opponent. A major penalty must be imposed under this rule for a foul resulting in an injury to the face or head of an opponent.
Match Penalty - The Referee, at his discretion, may assess a match penalty if, in his judgment, the player attempted to or deliberately injured his opponent by elbowing.
Game Misconduct Penalty - When a major penalty is imposed under this rule for a foul resulting in an injury to the face or head of an opponent, a game misconduct penalty shall also be imposed.“
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