The VAR Review: Toney's penalty vs. Liverpool; Newcastle offside

Is Nicol worried about Liverpool's injuries vs. Brentford? (1:29)

Steve Nicol reacts to Mohamed Salah's return and the injuries Liverpool picked up in their win vs. Brentford. (1:29)

Video Assistant Referee causes controversy every week in the Premier League, but how are decisions made, and are they correct?

After every weekend, we take a look at the major incidents to examine and explain the process both in terms of VAR protocol and the Laws of the Game.

- How VAR decisions have affected every Prem club in 2023-24
- VAR in the Premier League: Ultimate guide

In this week's VAR Review: Should Brentford have been awarded a penalty against Liverpool? Why did Newcastle United get a spot kick when the player was offside? Also, how Nottingham Forest will be angry with another decision that went against them.

Brentford 1-4 Liverpool

Possible penalty: Robertson challenge on Toney

What happened: Liverpool led 3-0 in the 72nd minute when Brentford's Sergio Reguilón attempted a cross in from the left. It was flicked on by Liverpool defender Ibrahima Konaté, with the ball dropping to Ivan Toney inside the area. The striker tried to control the ball on his chest, but he was knocked over by Andy Robertson from behind. Referee Michael Oliver signalled there would be no penalty, which was checked by the VAR, David Coote.

VAR decision: No penalty.

VAR review: It was judged as a coming together rather than a foul, with Toney moving into the defender's space as much as any possible foul contact. Yet the nature of Robertson's challenge should have been the important factor and led to a VAR review.

Toney did move backwards and to his left to chest the ball, and if Robertson had gone shoulder-to-shoulder with the challenge then no penalty would have been an acceptable outcome. Yet Robertson effectively jumps into the back of Toney, knocking him to the ground. Rather than it being a fair upper-body challenge, it's a foul and Robertson can have no control over the way he knocks the striker over.

Oliver may not have seen how Robertson made contact with Toney from his angle, but the VAR should have picked it up and told the referee to go to the monitor. Oliver has been involved in only one subjective VAR decision as a referee this season: the red card and penalty involving Tottenham Hotspur defender Cristian Romero vs. Chelsea.

Possible penalty: Jensen holding on Jota

What happened: Mathias Jensen was jostling with Diogo Jota inside the area in the 14th minute, with both players going to ground. Was there a case for a penalty? (watch here)

VAR decision: No penalty.

VAR review: Holding was taking place by both players, which means there should be no VAR intervention.

Last month, West Ham United's Jarrod Bowen wanted an injury time penalty after appearing to be dragged down by Sheffield United's Anel Ahmedhodzic. The widespread belief was it would be a missed VAR intervention, yet the main replay angles didn't show that holding was being done by both players as the ball came across. The Premier League's Independent Key Match Incidents Panel unanimously voted that the VAR was correct not to intervene.

Possible penalty: Collins challenge on Diaz

What happened: Luis Díaz broke into the penalty area in the 82nd minute and went down under a challenge from Nathan Collins. Referee Oliver waved away the penalty claims.

VAR decision: No penalty.

VAR review: While there was some contact on Diaz, the Liverpool player went to ground in a theatrical manner. The VAR will always look at how an attacking player reacts to contact.

If the referee had given the penalty on the field it would have stayed as a spot kick -- which underlines how "clear and obvious" can only underline inconsistencies in officiating. We've seen many soft penalties given by referees which won't get overturned yet wouldn't be given on review.

Newcastle 2-2 Bournemouth

Possible penalty: Challenge by Smith on Schär

What happened: Newcastle United had a free kick in the 53rd minute. A cross was played into the box and, after a melee, the delayed flag for offside was raised by the assistant. The VAR, Robert Jones, began a check for a possible penalty.

VAR decision: Penalty, scored by Anthony Gordon.

VAR review: When Kieran Trippier delivers the ball into the area, Fabian Schär is being pulled back by Adam Smith. Schär was having his shirt pulled for a sustained amount of time, and if holding starts outside the area and continues into it then a penalty should be awarded.

Schär was shown to be in an offside position, yet it's perfectly legitimate in law for a penalty to be awarded. Make sense?

In simple terms the law states that "it is not an offence to be in an offside position" -- ergo, it's what an offside player does once the phase is active which determines whether there's an offence. So, a player in an offside position can be fouled as long as they don't commit an offside offence before being fouled.

The logic is that a defender shouldn't have carte blanche to foul an opponent simply because they are stood offside. Yet it's contradictory in this specific situation, because the fouled player is being prevented from committing an offside offence.

While it's a correct decision, it feels like the remit of VAR has been stretched.

The VAR is supposed to take into account a player's ability to play or challenge for the ball being impacted before recommending a penalty review for holding. Yet Schär is unable to play or challenge for the ball because he'd become offside.

Even if a VAR intervention is technically correct, it feels like the boundaries have been pushed on when it should get involved. Such a complicated technical decision is better left to the on-field officials.

Almost five years ago to the day, Harry Kane won a spot kick for Tottenham Hotspur against Arsenal in similar circumstances -- though this was pre-VAR and given on the field. At the time the situation split opinion among high-profile former referees: some felt a penalty was correct; others disagreed.

Kane was bundled over by Shkodran Mustafi, so there was a much stronger case that the Spurs striker was already challenging an opponent when the foul took place. The Schär incident is clearer, as he is being pulled back and has no direct contact with an opponent.

The complicated nature of the decision is shown by the near-4½-minute review, as the officials first needed to determine that holding continued into the box, and also talk through the subjective aspect of Schär's offside status.

It took 2 minutes, 43 seconds for the VAR to send Michael Salisbury to the monitor, and another 1 minute, 23 seconds for the referee to confirm the penalty.

Nottingham Forest 2-0 West Ham

Possible penalty: Cornet on Williams

What happened: In the 81st minute, Neco Williams ran into the area under pressure from Maxwel Cornet. The Nottingham Forest player went down inside the box, but referee Thomas Bramall waved play to continue and Cornet came away with the ball. The VAR, Tim Robinson, checked for a possible penalty.

VAR decision: No penalty.

VAR review: When does a challenge in the area cross the necessary threshold for a VAR penalty? This provides a good case study and how different considerations can affect judgement.

You can understand how the referee missed the contact, as Cornet doesn't make a challenge for the ball or the opponent. Yet the West Ham United player stands on the left foot of Williams, causing him to stumble and go to ground.

The VAR will very rarely get involved where a defender hasn't attempted a challenge, usually leaving it on-field. Which begs the question of when unintended contact has the consequence to bring the VAR into action.

Is it a penalty if the referee gives it? Definitely. Is it a situation for the VAR? It should be. Yet the Premier League increasingly wants its VARs to only get involved in the most obvious of fouls, rather than those that could cause any debate.

Perhaps the VAR felt that Williams went down slightly late, but there was no delay in his running stride before the fall, and it should have been a penalty.

The VAR penalty Manchester United were awarded against Chelsea, when Enzo Fernández stood on the foot of Antony, was far less impactful on the opponent.

Tim Robinson was acting as a VAR in the Premier League for the first time this season, though he was on duty in the FA Cup last month. He previously worked in Stockley Park in the 2019-20 season, when PGMOL used EFL referees to act as VARs for some matches.

Manchester City 1-1 Chelsea

Possible penalty: Challenge by Sterling on Walker

What happened: Four minutes into the second half, Kyle Walker broke into the area, tracked by Raheem Sterling. Both players went to ground, with referee Andy Madley giving a free kick against the Manchester City player. (watch here)

VAR decision: No penalty.

VAR review: Walker was furious that he wasn't giving a spot kick, but it was a clear case of an attacker attempting to initiate contact. Sterling doesn't alter his running line, with Walker placing his left leg in front of the Chelsea player to try to invite a foul.

Possible penalty: Handball by Colwill

What happened: The game was four minutes into stoppage time when Bernardo Silva crossed in from the right. Erling Haaland headed the ball back across the box, and it hit the arm of Levi Colwill as he battled with Rúben Dias. Should the VAR have intervened for a penalty? (watch here)

VAR decision: No penalty.

VAR review: Axel Disasi misses an attempted header, with the ball dropping onto Colwill and Dias. Colwill is holding the shirt of the Manchester City player, and as his hand came off, his opponent it knocks the ball and there was no realistic reaction time.

When the replay is slowed down, it suggests it could be a deliberate act. Yet at full speed it's clear that the Chelsea player's arm is in a natural position for his movement. It cannot be compared directly to the two VAR penalties awarded in Luton Town vs. Sheffield United last weekend, with both players having their arms above shoulder height.

Penalties have not been awarded for this kind of handball situation in the Premier League. Of the five that have been given through VAR, all have involved the defending player either having his arm high or out creating a barrier to a shot or header.

Sheffield United 0-5 Brighton

Possible red card: Challenge by Holgate on Mitoma

What happened: Kaoru Mitoma carried the ball forward in the 11th minute, with Mason Holgate coming across to make a wild and high challenge. The Brighton & Hove Albion forward was brought down, with referee Stuart Attwell producing a yellow card. The tackle was checked by the VAR, Michael Oliver.

VAR decision: Red card.

VAR review: One of the quickest VAR reviews we're ever likely to see, with Attwell sent to the pitchside monitor just 15 seconds after he had cautioned Holgate.

Perhaps Attwell was unsighted as a player ran across him at the point of the contact. It was high with force, endangered the safety of an opponent and is exactly the kind of clear missed red card that VAR is here to catch.

Disallowed goal check: Osborn foul on Verbruggen

What happened: Sheffield United thought they'd pulled a goal back a minute before half-time when Ben Osborn scored from close range, but referee Attwell disallowed it for a foul on goalkeeper Bart Verbruggen. But was it the correct decision?

VAR decision: Goal disallowed for offside.

VAR review: The VAR quickly determined that while there was some contact between Osborn and Verbruggen, there wasn't enough for a foul. So for a few seconds at least, Sheffield United had been given the goal.

Yet the VAR then had to check a possible offside against Osborn, and the "deliberate play" law came back into focus.

Jack Robinson headed the ball back across the six-yard area, and it then accidentally touched the arm of another Sheffield United player, Vinicius Souza. It's not a handball offence, but it's the last time the ball is touched by a teammate before it falls to Osborn. It sets the offside phase, and at this point Osborn is clearly in an offside position.

Attwell had to be sent to the monitor to disallow a goal he'd already disallowed because there was a subjective element over the foul on the goalkeeper and Facundo Buonanotte's role. Did the Brighton player commit a "deliberate play," or was it a rebound off his body? The former would have reset the phase and played Osborn onside, but the ball just hit him and deflected to the goal scorer; the offside phase remains set at the touch by Souza.

As usual, the term "deliberate play" causes confusion, because in reality it means a "controlled" play.

Fulham 1-2 Aston Villa

Possible goal: No offside against Moreno

What happened: Aston Villa thought they had doubled their lead in the 39th minute when Álex Moreno headed home from Ollie Watkins' flick on, but the flag went up for offside.

VAR decision: No goal.

VAR review: It was a very tight decision, within millimetres of the attacking and defensive lines touching -- which would have made Moreno onside by the built-in tolerance level.

There was some confusion among Villa supporters, who believed it was drawn to Leon Bailey or Moreno's elbow. The plot point is the right edge of the red vertical line, which goes to the upper arm of Moreno, with which he would legally be able to play the ball..

This manual plotting of players to create a 3D graphic on a 2D image causes inconsistencies, and it's one reason the tolerance level exists to give the benefit to the attackers. Semi-automated offside should help to improve this, if the Premier League clubs vote to introduce it for next season.

Possible penalty: Challenge by Diop on Watkins

What happened: Bailey played Watkins into the area in the 65th minute, with the striker going down under a challenge from Issa Diop. The ball ran through to Fulham goalkeeper Bernd Leno, and referee Lewis Smith, taking charge of his first Premier League games, indicated play should continue.

VAR decision: No penalty.

VAR review: John Brooks was acting as the VAR for this game, and he supported the referee's view that this was a coming together between the players rather than a penalty.

Diop places his left leg across Watkins and takes a high risk of giving away a spot kick, yet Watkins also appears to edge into the Fulham defender. It could easily have been a spot kick, but is probably the kind of situation that has to be given on-field rather than through VAR.

Some parts of this article include information provided by the Premier League and PGMOL.