Throughout the game's history - from the days of round-arm to the modern era of 15-degree flexibility - bowling actions have stirred passionate debate and caused trouble for those accused of having suspect styles. This week we look at some of those who have come under the spotlight.
Throwing was the single biggest issue of last few years of the 19th century, and Lancashire's Arthur Mold was right at the heart of the storm. His record in first-class cricket was remarkable, but unrelenting questions about his action meant he made only three Test appearances. In 1900, Phillips finally no-balled Mold. That winter, the county captains voted to stamp out any chuckers, with Phillips the weapon by which they would do so. In 1901 Mold avoided games where Phillips was standing, until public pressure made a showdown inevitable and Lancashire bit the bullet and played him. Phillips duly called Mold 16 times and his career was over. He retired with the then-record for the most wickets by a fast bowler (1673 at 15.54) but with his reputation tarnished for good.
At a time when underarm was the order of the day, John Willes realised that delivering with a round-arm style created far more problems - the legend has it that he discovered this when his sister was forced to bowl at him with her arm at waist height, because the voluminous skirts that were then in fashion prevented underarm bowling. He tried to get this accepted, but the authorities responded by introducing a law in 1816 specifically banning it and allowing umpires to call a no-ball. Things came to a head at Lord's on July 15, 1822 when he opened the bowling for Kent against MCC and was no-balled. Willes had had enough. He threw the ball away, mounted his horse, and rode away, never to play again. But the popularity of the method spread, and in 1835 the laws were finally amended to permit the round-arm style which was already widespread.
Ernie Jones was probably the fastest bowler of his generation - he was the man who once sent the ball through WG Grace's beard at Lord's - but there were serious questions over his action. Some thought he was faultless - FS Jackson in his obituary for Wisden said such suggestions were "utterly absurd" - but others were unconvinced. At the time Jim Phillips, an Australian umpire who commuted between England and Australia to officiate, decided to take a stand against the scourge of throwing, with the tacit support of the authorities. In 1897-98, Phillips no-balled Jones in the opening match of the tour by AE Stoddart's side at Adelaide, and then in the Melbourne Test he again called Jones, who thus became the first person to be no-balled for throwing in a Test.
Charles Burgess Fry seemed to epitomise all that amateurism and the Corinthian spirit stood for. A remarkable allrounder - England footballer and cricketer, world-record holding athlete and scholar - he was considered in his youth to be the model of the ideal man. The only blot on his seemingly perfect record was his "eccentric" bowling action, but despite open debate in the press, the umpires, who were professionals, dared not to call a gentleman's action into question. Phillip's no-balling of Jones in 1897-98 moved the goalposts, however, and in 1898 Fry was called three times, on the second occasion by Phillips who mockingly referred to him as "CB Shy". Fry fumed, but Wisden described it as "long-overdue justice". When the county captains met to discuss the problem in 1900, Fry's name topped the list. To all intents and purposes, his career as an allrounder was over.
Tony Lock was a key part of the Surrey side which dominated the County Championship throughout the 1950s. Originally a conventional left-arm spinner, he developed a lower trajectory and quicker delivery which proved effective but controversial. He was no-balled in 1952, and then in the Caribbean in 1953-54 he was called during the Kingston Test. He continued to wheel away - Doug Insole, the Essex captain, once memorably asked a square-leg umpire if he had been bowled or run out - until he saw film of himself bowling in 1958 and and was genuinely shocked by the imperfection of his action. "Had I known I was throwing I wouldn't have bowled that way," he said later. He again remodelled his action, satisfying the critics and proving equally effective for almost another decade.
One of the saddest chucking tales, Griffin arrived with the 1960 South Africa side with his action already the subject of heated debate. The problem of throwing had resurfaced in the 1950s with a spate of bowlers whose actions were highly dubious. "The danger of not stamping on offenders in the past has led to the problems which now confront the authorities," Wisden noted. "They have only themselves to blame." Griffin was called early in the tour, underwent remedial work with coach Alf Gover, and seemed to have come back. In the second Test at Lord's, he took a hat-trick, but he was also no-balled 11 times, including one call in an exhibition match which followed the early finish to the Test. He finished by bowling underarm - and was promptly no-balled for not telling the umpire that he was changing his action! Two years later, he was repeatedly no-balled in a Currie Cup match and retired.
A number of Australian bowlers had been in the spotlight in the late-1950s and early-1960s, with Ian Meckiff and Gordon Rorke at the forefront. Meckiff had been the subject of unrelenting controversy for the best part of a decade, but somehow avoided being called. In 1958-59 England could hardly hide their dismay with his action, but the end came at Brisbane in 1963-64 when umpire Col Edgar called him four times in his first over against South Africa. Richie Benaud removed him from the attack, Edgar needed police protection from an angry crowd, and even before the match was over, Meckiff announced his retirement.
Harold Rhodes was one of the most controversial bowlers in the early 1960s, with his whippy action scrutinised and debated across England. Initially an offspinner, Rhodes tried legspin before turning to fast bowling. In 1959 he took two wickets in his first two overs on his Test debut, but by 1960 he was in the spotlight after being no-balled and his international career was over. When he was again called in 1965, the MCC held an assessment but were undecided as to whether he threw or not, with debate about his over-extended right elbow joint to the fore. The argument simmered - Sid Buller, who called him in 1965, asked that he be removed from the attack in a county game in 1966 - until MCC finally declared his action was legal in 1968. It made little difference as Rhodes retired at the end of the season, continuing to play league cricket in Nottinghamshire, with the occasional one-day outing for Notts.
Forming a formidable fast-bowling partnership with fellow Barbadian Wes Hall, Charlie Griffith struck fear into opposition batsmen in the 1960s. Whereas Hall was an out-and-out quick, Griffith was slower, but he possessed a lethal faster ball which many were unhappy with. In 1962-63 he was called while bowling for Barbados against the touring Indians - the match in which he fractured Nari Contractor's skull. By 1963-64 his action was widely discussed, and that winter the Australians made clear that they were deeply unhappy, even taking photos to support their claims. In 1964, England's Ken Barrington withdrew from a match in protest at his action - Ted Dexter, who was openly critical, considered doing the same. With umpires tending to agree, Griffith reined himself in and was never the same menace again.
Few incidents in recent years have caused as much controversy as Darrell Hair's decision to no-ball Muttiah Muralitharan for throwing in the Boxing Day Test at the MCG in 1994-95. Ross Emerson then did so in the one-day series that followed. Murali's action was passed by the ICC after biomechanical analysis at the University of Western Australia and at the University of Hong Kong in 1996 - they concluded that his action created the "optical illusion of throwing" but that didn't stop Emerson once again calling him when Sri Lanka toured in 1998-99. Murali was subsequently cleared for a second time, although the questions were never far from the surface.
David Gower was certainly not in the same league as any of the others on this list - indeed, it could be argued that he was one of the worst bowlers ever to have been unleashed on Test cricket. Nevertheless, he became the eighth person - and second Englishman - to be no-balled for throwing in a Test. He had few complaints. With New Zealand needing one to win in the second Test at Trent Bridge in 1986, Gower came on and openly threw his first ball which Martin Crowe smacked for four to end the game. But Ken Palmer at square leg called a no-ball, and so Gower ended with the figures 0-0-4-0.
By the time James Kirtley made his England debut he was already under scrutiny as he had been left out of an England A tour after doubts were raised. He was filmed by biomechanics experts and cleared by an eight-man ECB panel, but no sooner had he made his international debut, in a Harare one-dayer in October 2001, than suspicions were aired again by the match referee, Col Naushad Ali. With the backing of both the Sussex and England management, Kirtley carried on regardless, and returned to the side the following summer, following extensive remedial work. But he was reported twice in 2005 and again sent for remedial work at the end of the summer before again being cleared.