Joe Tennent’s facial injury: where does the risk of football end and negligence begin?

Football is, by its very nature, a physical sport. Tackles, challenges and collisions are an accepted part of the game. Players understand that participation carries an inherent risk of injury. But at what point does an ordinary football challenge become something for which a player may be legally responsible?

The recent injury suffered by Dartford FC defender Joe Tennent provides an interesting example of where that line might be drawn.

On 22 August 2026, Dartford faced Welling United in an Isthmian Premier Division fixture at Princes Park. During the first half, Dartford defender Joe Tennent was attempting to play the ball out from defence when he was challenged by Welling United striker Nahum Melvin-Lambert. Footage of the incident appears to show Melvin-Lambert moving towards Tennent at speed, and his right arm making contact with Tennent’s head. The referee awarded a yellow card to Melvin-Lambert as a result of the collision.

The decision to award only a yellow card has attracted considerable attention because of the severity of the resulting injury. Dartford subsequently confirmed that Tennent had suffered displaced facial fractures and would require cheekbone reconstruction surgery.

Dartford’s injury update indicated that Tennent would be out for the season, meaning the consequences extend well beyond missing a handful of matches. That is important when considering any potential personal injury claim. The significance of an injury is not limited to whether a player misses the next fixture. A serious facial injury may involve surgery, pain and suffering, rehabilitation, psychological consequences, loss of earnings and potentially longer-term consequences for the claimant’s ability to play football. Tennent’s circumstances are particularly notable given that football is central to his working life.

Does a footballer owe another player a duty of care?

The fact that an injury occurs during a football match does not mean that the injured player has automatically consented to every injury that happens to them. The law recognises that participants in competitive sport owe duties of care to one another.

Footballers owe one another a duty to take reasonable care, taking into account the circumstances in which the game is being played. That does not mean that every foul tackle, mistimed challenge or accidental collision amounts to negligence. Football is played at speed. Players have to make decisions in fractions of a second. A player can make an error of judgment without necessarily becoming legally liable for the consequences. The law therefore attempts to strike a balance.

On one side is the need to allow sport to remain competitive and physical. On the other is the need to prevent participants from using the nature of the sport as a justification for conduct which is excessively dangerous.

By choosing to play football, Tennent accepted certain risks. He accepted that he might be tackled. He accepted that he might collide with another player. He also accepted that he might even suffer an injury as an unfortunate consequence of a legitimate challenge. But that consent is not unlimited and does not mean that a player consents to every form of deliberate violence simply because it takes place on a football pitch.

A potential negligence claim would require Tennent to establish the following legal test: that Melvin-Lambert owed him a duty of care, that the duty was breached, that the breach caused the injury, and that the injury was not too remote.

The question is not simply ‘was Tennent injured while playing football?’; it is ‘did the incident go beyond the normal course of play?’, and was therefore one that Tennent could not have consented to just by participating in the game. This is a high bar given the inherent risks involved in sport, but some of the circumstances a court may consider in determining this would include:

• Was Melvin-Lambert genuinely attempting to play the ball?
• How much force did he use?
• Was the contact with Tennent’s head foreseeable?
• Was the use of the arm a natural part of the challenge or was it excessive?
• Was the level of force reasonable in the circumstances?

The most difficult question in Tennent’s case is breach. The fact that Melvin-Lambert received a yellow card rather than a red card would not, by itself, determine whether he was negligent. Sporting rules and disciplinary decisions can provide useful evidence about the nature of the conduct, but a breach of the rules does not automatically equal negligence. Similarly, the absence of a red card does not prevent a civil court from finding that the conduct fell below the legally required standard.

Additionally, the fact this was a non-league football match does not divert liability any more than a league football match would. This can be seen in Czernuszka v King (2023) EWHC 380 (KB), where King was found liable for injuries sustained by Czernuszka during an amateur rugby match.

English law recognises a duty of care between sporting participants. The standard is adapted to the realities of the sport, meaning that not every mistake or foul will result in civil liability. The crucial question is whether the conduct went beyond what a participant could reasonably be expected to accept as part of playing the game.

This article was written by Farida Hindi, trainee solicitor in the medical negligence and personal injury team.