Rivers United Letter To LMC – Appeal For Award Of 2nd Position In 2019/2020 NPFL

Rivers United have been vehemently remonstrating against the final 2019/2020 NPFL table officially released by the League Management Company (LMC), insisting it was wrongly prepared as the Port Harcourt side, not Enyimba, should be the second-placed team if the final table is prepared according the known football rules.

Below is a recent letter which Rivers United sent to the LMC, detailing their strong arguments and claims.

10th August, 2020

The Chief Operating Officer,
League Management Company.
Abuja.

Attn:
Chairman,
League Management Company.

Re: Rivers United FC’s Position On The Implementation and Calculation of the Nigeria Professional Football League (NPFL) Based on Points Per Game (PPG) Resolution at the Virtual Meeting of the Nigeria Football Federation (NFF) with Leaque Management Company (LMC) and NPFL Club Owners

We acknowledged the receipt of your letter dated 4th August, 2020 in reply to our position on the above subject, and shall address the matters raised sequentially in the following paragraphs:

1. Paragraph 2(1-4) is undisputed. The PPG system is neither novel, or creation of the LMC. With regards to paragraph 2(5), recall that the
representative of [Rivers United FC] RUFC drew attention in course of the Virtual Meeting to the fact that any calculation of the PPG that do not reflect fairness and justice will not be accepted by the Club.

2. In 2(5-7), it is not true that any table was presented at the meeting as official documents for deliberation. The only deliberation at the Virtual Meeting was for which method to be adopted in ending the league. At the end of the day, the PPG was adopted following votes cast by 20 teams. 18 teams voted for PPG, one team abstained from voting and the other one voted against to determining the ranking of clubs on the table. There was no mention of the use of WPPG at that meeting: therefore the claims are untrue. No table could have been presented at the meeting because as at the time of meeting, the decision to adopt the PPG had not been taken. It is therefore surprising how you knew the decision was going to be in favour of the PPG which prompted you to calculate the details, placing Enyimba in second place above Rivers United.

1. We admit that PPG is calculated by total points accrued, divided by total number of games played. It is however, not true that PPG does not take into account home and away matches in considering head-to-head as a means of untying two teams. We are therefore
constrained to challenge you to show documentary evidence in support of your claims to the effect that Head-to-Head rule can apply where the two affected teams in a “League Competition” have not played the first and reverse fixtures (8&9).

2. The rule of PPG are well known all over the world and the case of WPPG is not an issue in the circumstances, because we did not at any point agree to adopt WPPG.

3. It is not true that your argument in paragraph 2(1-2) is in compliance to the standard and principles validated by the precedence of the application of the PPG globally.

4. As provided in aticle 3, clause 15:24, the proposed use of the Head-to-Head rule to untie the two teams in this circumstance, defeats the principle of fairness and good sportsmanship because the two teams tied on second position, using the PPG model of calculation played only one game. The game in question was played on the ground of one of the affected clubs and the reverse fixture was not played, so the LMC deciding to go Head-to-Head is simply in bad faith.

The 2019/2020 NPFL final table (on PPG & WPPG) published by the LMC but being disputed by Rivers United

2019/2020 NPFL table as at Matchday 25 after the season was halted due to covid-19 pandemic

Furthermore, citing clause 15:25 of the NPFL rule to back up your argument that force majeure invalidates the rule is manifestly an erroneous argument to make. Force majeure should not provoke the abandonment of the rules on placement of teams. The leagues that the LMC gave as examples did not abandon their rules simply because the season ended abruptly via force majeure. The links you provided further invalidate your argument.

Link 2: Where the league was ended in Scotland, both St Mirren and Ross County were tied on PPG, and as the table clearly shows, St Mirren were placed ahead based on their superior GD of -17 to Ross County’s -31.

Link 3: In France, the head to head was used with the caveat that both matches between the teams had been played. Not a single match.

Link 5: In Italy, their rules already specify for head to head under normal circumstances and they stuck to those rules. They did not throw them out because of force majeure, or adoption of PPG

Link 7: The EFL also applied goals difference in both League One and League Two rather than head to head as enshrined in their domestic football rule book after the adoption of PPG.

5. By virtue of the provision of clause 3(5-7) of the NPFL rules, the Head to-Head rule is only applicable where the other two measures still result in a tie. It is not true that the rule book did not provide for resolution of a tie even in a force majeure situation. By the provision of the above cited, it is clearly stated that under any circumstance, the head-to-head rule can only apply in a particular trend. Ii can only be applicable where the goal difference rule, and the total number of goals scored could not resolve the tie. In this instance, the two mandatory steps were jettisoned in favour of a direct resort to the use of head-to-head which is inappropriate in this context.

6. Contrary to your paragraph 4, at the risk of repetition, the incident of force majeure is recognized in the rule book and also provided for and therefore applicable. Even the head-to-head rule resorted to by the LMC is a provision of the NPFL framework and rules book. You are only trying to bend the rule to suit your whims and caprices because of your pre-conceived intention to skip the recognized process of arriving at the application of the Head-to-Head rule. Our collective decision to adopt the use of PPG in this force majeure situation was to ensure fairness and good sportsmanship by enhancing the strength of those teams that played lesser number of games only. It does not apply to ties on the table except by finding their coefficient through goal difference, where it is adequate head-to-head, and lastly fairness as provided in the NPFL rule book. To buttress this point further, where the organizers of the league decide in their wisdom to adopt Head-to-Head to separate two teams that are tied, there is aways home and away games in the league situation already played to separate them, which is not the case in this circumstance.

Rivers United General Manager, Dr. Okey Kpalukwu

7. In your paragraph 6(1) there is no dispute about the circumstances of force majeure which you know is not a normal situation, and in the first instance necessitated the adoption of PPG. It is wrong to wish away all the provisions of the rule book associated with force majeure situations because of the adoption of PPG. Your response towards the adoption of Head-to-Head in ranking the teams on the table that are tied is faulty and has no basis and was done without regard to the provisions of the NPFL rule book. Again, we challenge you to provide precedents with similar facts to the matter in question, where an inconclusive Head-to-Head in any “league” globally was used in the situation of force majeure. All the instances where head-to-head was used in the league, were conclusive with home and away results.

8. Your submission in paragraph 6 (3) is grossly inaccurate. Where Head-to-Head is used to separate teams, there is no consideration anymore whether the teams played a lesser number of games because the use of PPG has put all teams at par, thus your choice of placing a team that played lower number of games above another team that had played more games is unjust, inappropriate and repugnant to the principle of fairness. Similarly, your claim that goal difference is only applied under the PPG principles if the teams on a tie have played
equal number of matches is a contradiction of your presentation. You may wish to recall that you queried earlier that there has never been a situation anywhere in the world where the use of PPG enabled goal difference to untie the teams. Refer to your paragraph 6 (2).

9. In your paragraph 6(4) you seem to have misconstrued our position and proposal. We are very clear in our argument that goal difference
be used as a first option to untie the teams on the PPG table as you earlier agreed in your paragraph 6{3) that goal difference is only applied under the PPG principles if the teams on a tie have played equal number of matches. Having adopted the PPG on the table, the result shows that the teams have all played equal number of matches. This elevation is what brought a team that finished 5th with lesser number of matches and points to tie on 2nd position on the table, with a team that played higher number of games and more points; in the spirit of fairness.

10. Our argument on the use of goal difference in this scenario as a first option is not necessarily to find coefficient of the two teams as to untie them through goals scored by goals conceded. But we are insisting that there are other ways of finding the coefficient on goal difference like number off goals difference divided by number of matches played. In order to rank the two teams tied together according to their strength without sentiment or bias as envisaged in the use of an inconclusive head-to-head to rank one above the other. “Assuming without conceding, even if the goal difference rule is to be applied, the appropriate formula to apply if you want to rank clubs based on goal difference, is to divide goals scored by the number of matches played by the club to get the goals coefficient, just the same way points accrued are divided by matches played to get the PPG coefficient. The scenario ensures each club is judged based on its performance, under an equal basis and thus meet the threshold of sporting merit and fairness for all clubs”. This is an extract from paragraph 6 (14) of your response to us dated 4th August, 2020 which clearly states the position of [Rivers United FC] RUFC on this issue. However, we are surprised that you knew about this but refused to ensure fairness and good sportsmanship.

11. In your paragraph 6(5), recall that a petition was sent to you since the 25th of June, 2020, despite several inquiries to your office on the source of the league tables all over the media in the country to which you acknowledged receipt and responded accordingly on the 4th of August 2020, about two months after. Why the long delay? – Thus your position that our reaction on this issue was an after-thought is not valid because we had no proof that the table circulated by the media was an official release by the LMC since it is not practical that a table will be released when the means of ending the league had not been adopted and ratified by the Nigerian Football Federation (NFF).

12. Your assertion in paragraph 7, is incorrect. We have perused the cases you provided as case study and found that where Head-to-Head was used to separate a tie as a result of the adoption of PPG, both home and away matches were played, with the result considered to measure the strength of both teams accordingly. In all of this, it is specified in their rule book that head-to-head shall be used to untie teams when the need arises. We challenge you to show evidence from the NPFL rule book where inconclusive head-to-head is the first option to be considered in untying teams.

13. It is unbelievable that you could refer to precedence without extensively studying the facts of the case in paragraph 8 where you made reference to the case of NICE and REIMS in the French Ligue1 where both clubs were tied on PPG coefficient and head-to-head was used to decide the ranking. Evidently, the first mode of resolution was the PPG coefficient which still resulted in a tie, then the head-to-head was used as provided in their rule book, not ours. The fact that a rule is applicable in one country does not mean it would automatically apply in another. It may interest you to know that the head-to-head in this case was conclusive. NICE defeated REIMS 2-0 at Allianz Riviera (Home), before drawing (1-1) in Champagne (away). In this scenario, the “force majeure” that caused the league to end abruptly, did not affect their head-to-head. Both games were played as opposed to our case where the head-to-head was affected by the “force majeure,” leaving one leg un-returned. The foregoing nullifies the LMC’s argument, re-enforcing Rivers United’s argument that head-to-head cannot and should not be applied when only one leg of a fixture has been played.

In conclusion, we still maintain our position that the Head-to-Head used to untie the teams is inconclusive and therefore invalidates the results obtained therefrom.

Based on the foregoing, it is quite clear that the LMC’s argument is based on:
a. Jettisoning its own rules under the guise of force majeure
b. Using examples from other leagues to justify its position

However, both positions have been proven to be flawed:
a. Leagues which cancelled early and applied PPG stuck to their initial tiebreaker rules as provided in their domestic football league rule book.
b. Where head-to-head was applied as tiebreaker, there is evidence
that the two contending teams had played their home and away matches before the force majeure.

Therefore, in the interest of equity, transparency, fair play. fairness, good sportsmanship and the overall interest of the game of football, the LMC MUST do the right thing after applying simple PPG by following its own rules and using the accepted standard coefficient of Goals Difference as a tiebreaker.

Other leagues have stuck to their rules in the face of force majeure, why should the LMC be different? Whether it is straight goals difference (13 to 10) or adjusted GDPG (0.52 to 0.50) Rivers United would be ahead of Enyimba.

On this ground, we do not accept the PPG table posted on the website of the League Management Company.

In the light of the above, we might be constrained to seek justifiable interpretation of this matter from the higher authorities in football
administration.

Yours faithfully,
Sir Dr. Okey Kpalukwu

General Manager
Rivers United

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