Judicial Action
Gary Gold
A SANZAAR Judicial Hearing conducted by Nigel Hampton QC (New Zealand) has found Cell C Sharks coach Gary Gold guilty of misconduct under the SANZAAR Code of Conduct following the Cell C Sharks vs Crusaders match 2 weekends ago.
Gold admitted a charge of misconduct, which also involved 2 breaches of the Super Rugby Competition Rules, by engaging with TMO (TMO) Johan Greeff during the 2nd half of the match.
In his finding Hampton concluded that, by his own admission, Gold had approached the TMO on 2 separate occasions (65th and 71st minutes) and had used crude and insulting language towards the official.
It was found that, by his actions, Gold had clearly breached Super Rugby Competition Rule 3.8 (7) “That no person may engage, or attempt to engage with a TMO during a match in relation to the TMOs officiating in the match.”
Hampton also found that Gold’s actions had breached the SANZAAR Code of Conduct Section 8.3 (l) which states: “All persons shall not use crude, insulting or abusive language towards Match Officials.”
Joe Marler
England prop Joe Marler has been banned for 2 matches and fined £ 20 000.00 by World Rugby for calling Wales forward Samson Lee “Gypsy boy”.
Marler, 25, had avoided punishment by The RBS 6 Nations organisers, but World Rugby conducted its own investigation.
He made the comment in England’s RBS 6 Nations win over Wales in March and had an apology accepted by prop Samson.
The Rugby Football Union said Marler would not appeal against the decision and considered the matter closed.
World Rugby, the sport’s global governing body, said it had “Exercised its right to take appropriate action before an independent judicial committee in the absence of such a process by Six Nations Rugby in accordance with the regulations”.
Joe Marler
England prop Joe Marler has avoided any sanction for striking an opponent during his side’s RBS 6 Nations win over Wales at Twickenham.
A Six Nations disciplinary committee found he struck prop Rob Evans in the 15th minute of Saturday’s match.
But it said in a statement: “The disciplinary committee found that the offending would not have warranted a Red Card and so imposed no sanction.”
Marler could now play in England’s final game against France on Saturday.
However, that could still be in doubt as the 25-year-old Harlequins forward may yet face action for calling Wales prop Samson Lee “Gypsy boy” in the same game.
Marler apologised to Lee – who is from the Traveller community – for that comment, and Lee has said he accepted the apology as “banter”.
Joe Marler
England and Harlequins prop Joe Marler has been cited for striking Wales prop Rob Evans in England’s 25 / 21 RBS 6 Nations victory over Wales at Twickenham.
Harlequins prop Marler appeared to land a forearm in the face of Evans while trying to assist Dan Cole ground the ball over Wales’s try-line.
“Joe Marler has been cited by the independent citing commissioner for allegedly striking an opponent in the 15th minute of the 1st half of the RBS 6 Nations match between England and Wales at Twickenham,” said an RBS 6 Nations statement.
If found guilty at a disciplinary hearing later this week, Marler will face an “entry-point” ban of 2 weeks, which would rule him out of England’s attempt to seal a 1st Grand Slam since 2003.
Officials have yet to decide whether a separate incident of verbal abuse, in which Harlequins prop Marler called Wales’s Samson Lee “gypsy boy” during the 1st half of England’s 25 / 21 win at Twickenham last Saturday, warrants disciplinary action.
Round 5 of the European Champions Cup produced an odd assortment of transgressions that resulted in citings – including abuse of a match official, eye-gouging, biting and testicle grabbing.
Viktor Kolelishvili:
Clermont Auvergne flank Viktor Kolelishvili heads the lengthy list of citings.
Kolelishvili was cited for his ill-advised decision to lay his hands on a referee in the match against the Ospreys at the Liberty Stadium last Friday, January 15.
Kolelishvili pushed the match referee, Wayne Barnes (England), in the 17th minute of the match in contravention of Law 10.4 (m).
The complaint was made by the citing commissioner Mike Rafter (England).
David Martin (Ireland) has been appointed as the judicial officer for the disciplinary hearing, which will take place in Paris on Tuesday.
Under Law 10.4 (m) – Physical abuse of match officials – a player could be banned for life, although low-end entry range is 24 weeks.
Jonny Gray
Ross Ford
Ross Ford and Jonny Gray (Scotland) are free to resume playing with immediate effect after successfully appealing against their 3-week suspension for acts of foul play contrary to Law 10.4(j) (dangerous tackles).
The appeal took place today at the London offices of the official law firm for Rugby World Cup 2015 Clifford Chance and was heard by an Appeal Committee, chaired by the Honourable Justice Lex Mpati (South Africa), sitting with Justice Graeme Mew (Canada) and Robbie Deans (New Zealand).
Having conducted a detailed review of all the evidence, including new submissions from the players and their representatives, along with all available camera angles, the Appeal Committee dismissed the finding that the players had committed an act of foul play as the player had not been dropped or driven and therefore the tackle was not dangerous.
Here’s a quick summary of the Diciplinary Sanctions imposed on cited players of remaining Quarterfinal Countries – Argentina, Ireland and Scotland – following the weekend’s last Pool Stage games in the Rugby World Cup of 2015.
- Marcelo Bosch of Argentina is suspended for 1 week, for a dangerous tackle
- Sean O’Brien of Ireland is suspended for 1 week, for striking a player
- Ross Ford of Scotland is suspended for 3 weeks, for his participation in a dangerous tip takle against Samoa
- Jonny Gray of Scotland is suspended for 3 weeks, for his participation in a dangerous tip takle against Samoa
Ireland flanker Seán O’Brien and Argentina centre Marcelo Bosch have been cited for alleged acts of foul play.
Jonny Gray
Ross Ford
Ross Ford and Jonny Gray are in danger of missing Scotland’s Rugby World Cup quarterfinal against the Australian Wallabies, after both were cited on Monday.
1st Choice hooker Ford and lock Gray, who forms an effective partnership with older brother Richie, have been cited for a lifting tackle during Scotland’s thrilling 36 / 33 win over Samoa on Saturday.
Their hearing will take place in London on Tuesday morning and will be heard by English lawyer Christopher Quinlan.
England coaches Andy Farrell and Graham Rowntree will have restricted access to the England changing room and tunnel for England’s final Rugby World Cup 2015 Pool A match against Uruguay after being found to have breached the Match Officials Protocol that regulates communication between team members, coaches and match officials on match day. The breaches occurred during England’s match against Australia at Twickenham on 3 October.
Following submission of the usual post-match report, which identified the incident, members of the England coaching staff were investigated by the Rugby World Cup Disciplinary Officer for an alleged breach of the Match Officials Protocol, which prohibits unauthorised contact between coaches and team members with match officials on match day, in order to protect the integrity of the game. This includes the pre-match and halftime periods, which is when contact between Farrell, Rowntree and the assistant referees occurred.
Mihai Macovei
Romanian captain Mihai Macovei will miss his country’s pivotal final Pool D match with Italy on Sunday after being suspended for a fortnight for a dangerous tackle.
The 28-year-old loose forward was hailed as a hero earlier in the week for his 2 tries in Romania’s superb comeback from 0 / 15 down to beat Canada 17 / 15 and set his team up for Sunday’s match where the winner will seal 3rd place and automatic qualification for the 2019 World Cup.
However, he fell foul of the citing commissioner and has now been found guilty of a dangerous tackle during the Canada match.
“Mihai Macovei has been suspended for 2 weeks for a dangerous tackle contrary to Law 10(4)(e),” read the statement from the disciplinary commission.
Stephen Betham, Samoa head coach
Samoa coach Stephen Betham claimed Thursday the Pacific island teams had been singled out over rough play and were warned about their discipline before the Rugby World Cup began.
As the penalties and Yellow Cards mount up against Samoa, Fiji and Tonga, Betham said the teams were “tainted. We were warned at the start.”
His outburst came as Samoa considered appealing a 5-week ban on Alesana Tuilagi for kneeing Harumichi Tatekawa as the Japanese player tried to tackle him.
The judicial ruling has been widely criticised on social media by former players as video replays indicated a problem with the technique of the much smaller Tatekawa as he tried to stop Tuilagi in full flight.
“We are feeling the pain,” Betham said of not being able to field the giant Newcastle wing in their final pool game against Scotland on Saturday.
Alesana Tuilagi
Samoa wing Alesana Tuilagi has been suspended for 5 weeks for striking a player with his knee in their game against Japan.
It means he will not be available for Samoa’s final pool fixture against Scotland on Saturday and will not be available to turn out for his Newcastle Falcons club side before 10 November.
Tuilagi was cited for kneeing Harumichi Tatekawa in the 2nd minute of the match, won last weekend by Japan by 26 / 5.
He denied foul play. But after reviewing all camera angles the citing was upheld by judicial officer Antony Davies.
Israel Folau in the air, against England
Australian Wallabies star Israel Folau is battling to be fit for their final Pool A clash – the table-topping decider with Wales.
Assistant coach Stephen Larkham delivered the bad news to the media.
Folau, lynchpin of the Wallabies formidable backline, did not train on Monday, but got a run out on Tuesday.
The 25-year-old is still feeling the effects of the knock to the ankle that forced him to quit the action in the devastating 33 / 13 defeat they inflicted on hosts England last Saturday.
While he is still in the game to play the Welsh, little hope is given to wing Rob Horne, who left the England match in the 10th minute because of a shoulder injury.
Rayno Benjamin
Toyota Free State Cheetahs utility back Rayno Benjamin has escaped all sanction after he appeared before a SARU Judicial Hearing late on Monday afternoon.
According to the SARU Regulations, a player must appear before a judicial hearing after receiving 2 Yellow Cards in 1 match or 3 overall in a competition.
Benjamin was shown 2 Yellow Cards in their match against the Steval Pumas in Nelspruit in Round 9 of the Currie Cup – 1 for a dangerous tackle and another for a team offence, resulting in a Red Card.
He also received a Yellow Card against DHL Western Province earlier in the competition, to take his total tally to 3 in the competition.
His hearing was held late via teleconference before Duty Judicial Officer advocate Rob Stelzner, who decided not to impose any further sanction on the player.
Benjamin was therefore deemed available for selection for the Toyota Free State Cheetahs’ home fixture against the Cell C Sharks in Bloemfontein on Saturday.
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Alesana Tuilagi
Faifili Levave
Samoa’s hopes of rescuing something from a wretched Rugby World Cup campaign suffered a new blow after Faifili Levave and Alesana Tuilagi were cited over incidents during Saturday’s defeat by Japan.
Levave was sin-binned for the offence he has been cited for by independent Citing Commissioner Yves Thieffine, which is for “playing the opponent without the ball”.
Tuilagi, who enjoyed a successful spell with Leicester Tigers finishing leading try scorer in 2012, has been cited for an offence which was not seen at the time by South African referee Craig Joubert.
Tuilagi was accused of an alleged foul “striking with the knee” in the 2nd minute of the Pool B match in Milton Keynes, said a World Rugby statement. Japan won the game 26 / 5.
Michael Hooper
Australian Wallabies flank Michael Hooper could miss the Pool A decider with Wales after being cited over an incident during their crushing 33 / 13 defeat of England.
The incident concerning the 23-year-old – who along with fellow back row forward David Pocock were outstanding against England – took place in the 39th minute when he flung himself into a ruck leading with his shoulder which resulted in just a ticking off by French referee Romain Poite and a penalty being awarded to England when it was deep inside their own 22.
However, the independent citing commissioner Steve Hinds decided further action should be taken.
“Michael Hooper has been cited for an alleged act of foul play contrary to Law 10.4(h) – Charging into a ruck or maul without use of the arms or grasping the player – during the 39th minute of the Rugby World Cup 2015 Pool A match between England and Australia at Twickenham on Saturday, 3 October,” read the statement form the organisers.
Hooper’s hearing will take place on Tuesday morning in London and be heard by independent Judicial Officer Alan Hudson.
Mariano Galarza
Rugby World Cup disciplinary chiefs on Wednesday banned Argentina’s Mariano Galarza for 9 weeks, excluding him from the rest of the tournament, after an incident with New Zealand’s Brodie Retallick.
Galarza was found guilty of making “contact with the eye or eye area” of Retallick during the Pumas 26 / 16 defeat by the world champion All Blacks at Wembley on Sunday.
The giant Argentine, 28, denied the charge. He did not get the maximum sentence because of his good disciplinary record up to now.
Hansie Graaff
Eastern Province Kings fullback Hansie Graaff was suspended for 1 match, after being found guilty of striking an opponent in their Currie Cup Premier Division clash against the Xerox Golden Lions in Johannesburg last Saturday.
As a result of the sanction he will miss the EP King’s next match against the Toyota Free State Cheetahs in Port Elizabeth on Friday evening.
Michael Hooper
A SANZAR Appeals Committee, chaired by Jannie Lubbe SC (South Africa) and comprising Terry Willis (Australia) and Mike Heron QC (New Zealand) unanimously dismissed both appeals brought by SANZAR and the Australian Rugby Union (ARU) on behalf of Michael Hooper.
The Committee dismissed the ARU appeal on behalf of Michael Hooper on the basis that the appellant was unable to show that the Judicial Officer erred in law in finding that Hooper’s striking of Nicolas Sanchez from Argentina was a breach of Law 10.4 (a).
The Committee also dismissed the appeal brought by SANZAR that the Judicial Officer’s sanction of 1 week was unduly lenient. The Committee found the Judicial Officer was correct in the exercise of his discretion that the offending was low-end.
As such, the player’s suspension from all forms of the game for 1 week was confirmed.
Michael Hooper
An appeal has been lodged against the outcome of a judicial hearing held on Wednesday 29 July and Thursday 30 July, which found Michael Hooper of Australia’s Wallabies guilty of contravening Law 10.4 (a) and issued a sanction of a 1 week suspension.
Under the SANZAR Judicial Rules, all formal judicial hearings are reviewed by an independent Appeals Review Officer. The review officer, the Honourable Graeme Mew (Canada), has examined the Hooper case and in his determination, referred it to a SANZAR Appeals Committee to review the sanction handed down by Judicial Officer Nigel Hampton QC.
A SANZAR Appeals Committee, chaired by Jannie Lubbe SC, with Terry Willis and Mike Heron QC as members, will hear the appeal via videoconference on Sunday 2 August 2015 at 17:00 AEST (19:00 NZ Time, 09:00 SA Time, 07:00 GMT, 04:00 ARG Time).
Michael Hooper
Wallabies flank Michael Hooper will have to wait at least 1 more day to find out if he will be available for his team’s Rugby Championship decider against the All Blacks.
Hooper appeared before a SANZAR judicial hearing on Wednesday, where he was charged with having punched Argentina flyhalf Nicolas Sanchez in his team’s 34 / 9 win over the Pumas at the Estadio Malvinas Argentinas at the weekend.
Hooper was cited to appear before Nigel Hampton – via video conference – on Wednesday.
The Wallaby is alleged to have contravened Law 10.4 (a): Punching or striking.
The hearing has been adjourned until Thursday 30 July.
Michael Hooper
Michael Hooper of Australia’s Wallabies has been cited for alleged foul play during a Rugby Championship match at the weekend.
Hooper is alleged to have contravened Law 10.4 (a) Punching or striking, when he made contact with Los Pumas flyhalf, Nicolas Sanchez in an incident that occurred in the 59th minute of the match between the Pumas and Wallabies at Estadio Malvinas Argentinas in Mendoza on 25 July.
The case is to be considered in the first instance by SANZAR Duty Judicial Officer Chris Morris.
All SANZAR disciplinary matters are in the first instance referred to a Duty Judicial Officer hearing to provide the option of expediting the judicial process.
For a matter to be dispensed with at this hearing, the person appearing must plead guilty and accept the penalty offered by the DJO.
Henry Speight
A SANZAR Appeals Committee, chaired by Nigel Hampton QC (New Zealand) and comprising Lex Mpati (South Africa) and Terry Willis (Australia) unanimously dismissed an appeal brought by the Brumbies against the decision that found Henry Speight had contravened Law 10.4 (j) – Lifting Tackle.
The Committee dismissed the appeal on the basis that the appellant was unable to show that the Judicial Officer’s central factual findings, that the tackle involved both a lifting and driving, were in error.
The Committee also unanimously dismissed the appeal brought against the 5-week (4-match) suspension imposed on Speight, finding that the Judicial Officer had not erred in principle and that the sanction imposed was not manifestly excessive.
As such, the player remains suspended from all forms of the game for 5 weeks up to and including Saturday 25 July 2015.
Henry Speight
The Brumbies will appeal Wallabies wing Henry Speight’s 5-week suspension after the Aussie side felt the player was treated harshly compared to other lifting tackles this season.
Speight was found guilty of contravening Law 10.4 (j): Lifting Tackle, on Wednesday and will be out of action up until 25 July, which translates into 4 matches.
His tackle on DHL Stormers’ centre Juan de Jongh in the 74th minute of the qualifier last Saturday, resulted in the Springbok landing on his head.
Speight will be out for the remainder of the Super Rugby season and will also miss the Wallabies 1st 2 Tests of The Rugby Championship against South Africa and Argentina.
The Brumbies will appeal the suspension on 2 grounds – the severity of the punishment and the incident’s classification as a lifting tackle.
Henry Speight
A SANZAR Judicial Hearing has found Henry Speight of the Brumbies guilty of contravening Law 10.4 (j) Lifting Tackle, after he received a red card during a Super Rugby match at the weekend. Speight has been suspended for five weeks up to and including Saturday 25 July 2015, which translates into four matches.
The incident occurred in the 74th minute of the match between the Stormers and Brumbies at DHL Newlands in Cape Town on 20 June 2015.
The SANZAR Judicial Hearing was heard by Robert Stelzner SC via video conference at 4:00pm AEST, 6:00pm NZST, 8:00am SAST on 23 June 2015. Mike Mika was the former professional player who attended as a Judicial Technical Adviser. The outcome was delayed as Stelzner requested information of the player’s forthcoming playing schedule in order to determine the sanction.
In his finding, Stelzner ruled the following:
“As the Judicial Officer, I considered all the evidence before me including the video footage of the incident, referee and TMO reports for issuing the red card and the submissions made for the player by his legal representative, Peter McGrath.
Robert du Preez
André Esterhuizen
DHL Stormers’ fullback Robert du Preez and Sharks centre André Esterhuizen have both been handed lengthy suspensions after performing dangerous tackles in their game on Saturday.
The Sharks won the match 34 / 12 in Durban.
Du Preez has been suspended for 6 weeks – after being shown a Yellow Card for his dangerous tackle on Sharks’ wing Lwazi Mvovo in the 76th minute, while Esterhuizen got 4 weeks after his tackle on Stormers flank Michael Rhodes in the 10th minute.
Both players were found guilty of contravening Law 10.4 (j): Lifting a player from the ground and dropping or driving that player into the ground whilst that player’s feet are still off the ground such that the player’s head and / or upper body come into contact with the ground is dangerous play.
Judicial officer Nigel Hampton deemed that with Du Preez the offence was more serious and thus handing the player a longer suspension.
Sonny Bill Williams
Sonny Bill Williams has been issued with a Citing Commissioner Warning for a dangerous tackle.
The Chiefs centre was warned for contravening Law 10.4 (e) Dangerous tackling during the clash with the Hurricanes in New Plymouth on Saturday.
The incident occurred in the 40th minute at Yarrow Stadium, but was not serious enough to warrant further sanction.
A young Canterbury club player has been banned from all rugby for 2 years for possessing a human growth hormone.
Finn Hart-Strawbridge pleaded guilty to possessing the drug, GHRP-6, in a case heard by New Zealand Rugby’s Judicial Committee. .
The peptide stimulates the production of human growth hormone and has been found in nutritional supplements.
A 5mg vial of the peptide that the Canterbury Under 19 had in his possession was seized by NZ Customs in October last year.
The substance is prohibited in and out of competition under World Rugby and New Zealand Rugby Anti-Doping Regulations. Hart-Strawbridge said he had ordered the peptide online as a “joke” after reading a series of articles in the New Zealand Herald last year about a reporter who experimented with the drug.
He told the committee he didn’t realise that importing the substance breached the regulations and quickly realised he had made a mistake after attending a DFSNZ education seminar.
Laurie Weeks
Melbourne Rebels prop Laurie Weeks has been suspended for 3 weeks after he was found guilty for punching Cell C Sharks prop Jannie du Plessis in their Round 16 encounter.
The sanction means that Weeks will play no further part in this year’s competion as his team only has 2 games left.
Weeks was found guilty under Law 10.4 (a): Punching or striking, after he was sent off during a Super Rugby match at the weekend.
The incident occurred in the 29th minute of the match with footage showing Weekes throwing a flurry of punches to Du Plessis’ head.
Weeks has been suspended from all forms of the game for 3 weeks up to and including 20 June 2015.
Laurie Weeks
Melbourne Rebel prop Laurie Weeks is facing a lengthy ban in the wake of his brain explosion against the Cell C Sharks at the weekend.
Weeks was handed a Red Card in his team’s 21 / 25 loss to the Sharks in Durban on Friday.
The Rebels prop launched a flurry of punches on Sharks rival Jannie du Plessis, after the latter had slapped him with an open hand against the back of the head.
Du Plessis was Yellow-Carded for his part in the ensuing fracas, which happened just short of the half-hour mark, while Weeks was shown a Red Card for landing about 10 punches on various parts of Du Plessis’ head.
Weeks will be have to appear before a judicial officer and will be charged with having contravened Law 10.4 (a): Punching or striking.
Robbie Coetzee
Emirates Lions’ hooker Robbie Coetzee has been suspended for 3 matches after he was found guilty for performing a dangerous spear tackle on Cheetahs replacement wing Rayno Benjamin.
The ruling means the burly forward will play no further part in this year’s campaign if his side fails to make this year’s playoffs as they only have 2 games remaining.
Coetzee has been found guilty under Law 10.4 (j): Lifting a player from the ground and dropping or driving that player into the ground whilst that player’s feet are still off the ground such that the player’s head and / or upper body come into contact with the ground is dangerous play.
Elapsed time in match when incident occurred: 49th minute.
“I considered all the evidence before me including the video footage, Citing Commissioner’s report, medical information for the Cheetahs’ player, Rayno Benjamin, who was involved in the incident and the submissions made for the player by his legal representative, Frikkie Erasmus and Lions Defence Coach, JP Ferreira,” Judicial Officer Robert Stelzner said.
“After taking further facts into consideration, such as the player’s unsuccessful attempt to hold on to his opponent in the tackle, I found the incident to have a lower end entry point. A 4 week suspension is indicated for such offending.
“The need for a deterrent in the circumstances of this incident is in my view served by imposing a further week’s suspension.”
Will Skelton
Tolu Latu
The Waratahs have formally appealed against the bans slapped on 2 of their players and the new hearing will take place on Thursday.
The judicial hearing held on Monday 25 May found Will Skelton and Silatolu (Tolu) Latu guilty of contravening Law 10.4 (j): Lifting a player from the ground and dropping or driving that player into the ground whilst that player’s feet are still off the ground such that the player’s head and / or upper body come into contact with the ground is dangerous play.
Skelton was given 2 weeks and Latu handed 4, for spear tackling Crusaders’ lock Sam Whitelock.
Tolu Latu
Will Skelton
2 Waratahs players were cited and suspended after the niggly Waratahs display on the weekend in their match against the Crusaders. Will Skelton was suspended for 2 weeks and Tolu Latu for 4 weeks.
It appears that the Waratahs will appeal the findings of both Hearings.
Will Skelton:
A SANZAR Judicial Hearing has found Will Skelton of the Waratahs guilty of contravening Law 10.4 (j) Lifting Tackle, after he was cited following a Super Rugby match at the weekend. Skelton has been suspended for 2 weeks up to and including Saturday 6 June 2015.
The incident occurred in the 17th minute of the Super Rugby match between the Waratahs and Crusaders at ANZ Stadium in Sydney on 23 May 2015.
The SANZAR Judicial Hearing was held by Robert Stelzner SC via video conference at 15:30 AEST (17:30 NZ Time, 07:30 SA Time) on 25 May 2015. Mike Mika was the former professional player who attended as a Judicial Technical Adviser.
James Lowe
Chiefs wing James Lowe has had no further sanction imposed by the SANZAR Duty Judicial Officer after receiving a 3rd Yellow Card.
Lowe was sent to the sin bin in the Chiefs’ 15 / 16 defeat to the Melbourne Rebels in Melbourne for striking centre Tamati Ellison with his knee.
According to the SANZAR Judicial Rules a player who has received 3 Yellow Cards or 3 Citing Commissioner Warnings (or any combination thereof) arising from matches in the same season shall be required to appear before the Duty Judicial Officer appointed for the match during which he last offended.
The Duty Judicial Officer then considers the circumstances in which each Yellow Card and / or Citing Commissioner Warning was imposed and determine whether any further penalty should be imposed on him by reason of his persistent foul play.
SANZAR Duty Judicial Officer Nicholas Davidson heard the case and ruled that there should be no further punishment for Lowe.