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I think any hair pulling incident is going to be deliberate - I can't see how someone can accidentally pull someone's hair. If you attempt to pull their shirt, for example, but grab their hair - you have still deliberately pulled them by the hair. It doesn't need to be sustained, it just has to be more than negligible force. From memory, Keane's was definitely more than negligible force - I'm just not convinced this one clears the very low threshold for it to be deemed VC.As with the Keane one, the force is negligible and there could be an element of doubt it was fully intentional to go for the hair. For me to be classed as violent conduct, it has to be deliberate, sustained and some evidence of force for a sending off. The Jack Stephens one last season is a good example where using the guidance is correct because whilst the force was not too strong, it was deliberate and there is no doubt it was a clear hair pull.
I guess the counter argument would be, just don't put your hands anywhere near someone's hair and there would be no issues.