The concept gained notoriety in association football after an infamous incident in the 1980 FA Cup Final when Willie Young of Arsenal committed a deliberate foul on Paul Allen of West Ham, when Allen had a clear run at goal. As the Laws of the Game stood, the referee (George Courtney) could only caution Young and award West Ham a free kick, which he did. This provoked a national debate on deliberate fouls that denied opponents the chance to score a goal.