1 Introduction
Rules are a defining and indispensable feature of sports. As Vamplew writes: ‘It is rules that differentiate one sport from another. It is also rules that distinguish the sophisticated games of sport from the more naïve ones of play.’Footnote 1 A sport’s rules dictate by whom and how it is played; they seek to ensure that the on-field contest is free from corrupting influences such as doping or match-fixing; and they set standards of behaviour that players – and indeed others involved in the sport – must conform to, both on and off the field of play.
Among other purposes, and depending on the sport, the rules are in place to protect the participants’ safety, ensure fair competition, and maximise the sport’s enjoyment and entertainment value for those participating and spectating. The latter function is particularly important in tennis, a sport which places an emphasis on player decorum to maintain its character and aesthetic appeal to participants, spectators and sponsors. Lake describes tennis as ‘a sport characterized and self-regulated by an unwritten code of sportsmanship and restrained gentlemanly behavior since its inception in the mid/late nineteenth century’.Footnote 2 As Lake points out, ‘key aspects of the traditional code of conduct were modelled on British amateur ideals’.Footnote 3 The historical development of tennis was grounded in its middle-class roots, and the behavioural and aesthetic expectations of the sport continue to reflect this: ‘The cultural expressions of upper-class taste sought by the most aspirational upper-middle-class players had a lasting impression upon the sport. From its very beginnings, principally because of its noble heritage … and also due to its earliest upper-class enthusiasts, lawn tennis attracted those seeking to improve their social positions.’Footnote 4
This chapter looks at the rules governing participant behaviour that are contained in the International Tennis Federation (ITF) World Tennis Tour Code of Conduct (hereinafter, the ‘Code’).Footnote 5 The Code is the principal basis for disciplinary action in tennis,Footnote 6 with some variations where a matter falls under the jurisdiction of the Association of Tennis Players (ATP), the Women’s Tennis Association (WTA) or the organisers of the four Grand Slam tournaments, with each having their own ‘Rulebooks’.Footnote 7 The Code augments and operates alongside the ITF’s ‘Rules of Tennis’,Footnote 8 which ‘constitute and define what counts as playing’ tennis.Footnote 9 Foster refers to the rules of the game as ‘lex ludica’, the composition, adjudication and enforcement of which are matters almost entirely within the control of a given sport’s governing bodies. The Court of Arbitration for Sport (CAS), for example, does not generally accept appeals or otherwise interfere in disputes over the interpretation and enforcement of these rules.Footnote 10 Sports governing bodies therefore form a kind of ‘private government’,Footnote 11 and the ITF enjoys great power in the devising, promulgation and enforcement of its rules, including the Code.Footnote 12
2 The Code
The ‘Rules of Tennis’ acknowledge the need to strike a balance between maintaining tradition and the development of the sport. This is set out explicitly in the ‘objectives’ cited in Appendix XIII, which state that the ITF is committed to:
a. Preserving the traditional character and integrity of the game of tennis.
b. Actively preserving the skills traditionally required to play the game.
c. Encouraging improvements, which maintain the challenge of the game.
d. Ensuring fair competition.Footnote 13
This idea of ‘[p]reserving the traditional character and integrity’ while ‘encouraging improvements’ is therefore central to the regulation of tennis. The Code is a key means to achieving this; its purpose is set out in Article I(A) as follows: ‘The International Tennis Federation promulgates this Code of Conduct … in order to maintain fair and reasonable standards of conduct by players, Related Persons, Covered Persons and the organisers of Men’s and Women’s ITF World Tennis Tour tournaments, and to protect their respective rights, the rights of the public and the integrity of the Sport of Tennis.’Footnote 14
Serious integrity breaches are beyond the scope of the Rules of Tennis or the Code (and of this chapter).Footnote 15 Until 2021, the ITF (in conjunction with the WTA, ATP and Grand Slams) oversaw the Tennis Integrity Unit, which administered the integrity rules related to doping, match-fixing and other forms of corruption. From 2021, this is the responsibility of the International Tennis Integrity Agency (ITIA), which describes itself as ‘an independent body established by the international governing bodies of tennis to promote, encourage and safeguard the integrity of professional tennis worldwide’.Footnote 16 To this end, the ITIA administers the Tennis Anti-Corruption Program (TACP) and the Tennis Anti-Doping Program (TADP). Breaches of the integrity rules can have serious consequences for the offender, including large fines and lifetime bans from participation in the sport. Because of this, there are appeals mechanisms in place, which involve independent tribunals and the potential for an appeal to the CAS. It should be noted that the behaviours captured by these codes may also comprise criminal offences.
Contravention of the Code can lead to the imposition of penalties. These range from in-game sanctions (warnings, points penalties, forfeiture of games or even matches) to (usually more severe) out-of-game punishments, such as fines, disqualification from tournaments, suspensions or even participation bans. Although this chapter is concerned primarily with on-court player misconduct, it is important to note that the applicability of the Code goes well beyond this, both in terms of the conduct it captures and the ‘covered persons’ who are subject to it. This breadth of application can be seen in the case of Ilie Năstase, who was punished in his capacity as Romanian Fed Cup captain for misconduct in the build-up to and during a home tie against the Great Britain team in April 2017 in Constanta, Romania.Footnote 17 The misconduct comprised: a comment made in relation to Serena Williams’s pregnancy that the ITF alleged was ‘unethical, unprofessional, unacceptable, offensive, derogatory, and may be interpreted as racist’; repeated and unwelcome sexual advances towards GB team captain Anne Keothavong; alleged intimidation of the GB players;Footnote 18 repeated abuse of the media; repeated accusations of umpire bias during the match; and abusive language directed at the umpire and the GB team.Footnote 19
At a hearing before the ITF Internal Adjudication Panel (IAP) in July 2017, Năstase was found guilty of several breaches of the Fed Cup Welfare Policy, which reproduced in identical language the behavioural standards set out in the ITF Code of Conduct’s Welfare Policy.Footnote 20 The IAP imposed a fine of $10,000 and a two-part suspension. The first part of the suspension applied to Năstase’s attendance at ITF events and was for one year and eight months. The second part of his suspension related more narrowly to his ‘acting in an official capacity’ at ITF-sanctioned events and was for the longer duration of three years and eight months. Năstase appealed the decision of the IAP to the Independent Tribunal, which upheld the original decision, but altered the penalty. The fine was doubled (from US$10,000 to US$20,000), but both periods of suspension were reduced by around eight months, to one year and three years, respectively.
2.1 Code Violations
Năstase’s case demonstrates the breadth of application of the Code, but this chapter is centrally concerned with the regulation of players’ on-court behaviour. The type of conduct that might lead to sanctions is captured in the following list of common Code violations:
Audible Obscenity
Visible Obscenity
Racket Abuse
Ball Abuse
Verbal Abuse
Physical Abuse
Coaching
Time Violations
Dress Code Violation
Failure to Give Best Effort
Unsportsmanlike Conduct
In-game violations are punished according to the ‘point penalty schedule’ set out in Article IV(R) of the Code.Footnote 21 According to this, a player’s first offence during a match will result in a ‘warning’. Subsequent Code violations will result in a ‘point penalty’, then a ‘game penalty’. Any further violations may result in default for the offending player, meaning that the player will be disqualified from the match and victory awarded to the opponent. The decision as to whether to impose a default rests with the ‘ITF Supervisor’.Footnote 22 A sufficiently serious Code violation can result in a player receiving an ‘Immediate Default’, even where this is the first Code violation of the match.Footnote 23 Importantly, the Code sets out that decisions made under the point penalty schedule or to declare a default are ‘final and unappealable’.Footnote 24
2.1.1 Physical Violence
The Code provisions listed above are concerned primarily with maintaining the aesthetic and fairness of the competition. A study of junior tennis players that looked at the prevalence and causes of norm-breaking behaviours found that norm-breaking behaviours were a stress response to an individual psychological crisis.Footnote 25 By far the most common manifestations were ‘behaviours directed toward property’ (37 per cent of the incidents) and ‘self-directed verbal behaviours’ (33 per cent of the incidents). There is relatively little concern for interpersonal physical violence. The Code violation of ‘physical abuse’ is defined as ‘the unauthorised touching of an official, opponent, spectator, or other person’. The relevant offence entails ‘the unauthorized touching of any official, opponent, spectator, or other person within the precincts of the tournament site’.Footnote 26 In his study of the prevalence and types of violence that manifest in different sports, Guilbert notes that interpersonal physical violence is rare in tennis.Footnote 27 The format and nature of the sport preclude it, since the opponents are separated by a net and the sport does not involve contact between them. In an exceptional example of causing injury through physical violence, in 2012, at the Queen’s Club Championships, David Nalbandian injured a line judge by frustratedly kicking an advertising board into the judge’s shin and drawing blood. Code violations that involve physical violence are more likely to be captured under the offences of ‘abuse of ball’, ‘abuse of racquet or equipment’ or ‘unsportsmanlike conduct’.
The Code sets out the offence of ‘abuse of balls’ as follows: ‘Players shall not violently, dangerously or with anger hit, kick, or throw a tennis ball within the precincts of the tournament site except in the reasonable pursuit of a point during a match.’ This is defined as ‘intentionally hitting a ball out of the enclosure of the court, hitting a ball dangerously or recklessly within the court or hitting a ball with negligent disregard of the consequences’.Footnote 28 The most notorious and heavily punished offences involving such behaviour arise out of those relatively rare instances where a ball is hit in anger or frustration and ends up striking another person.
In 1995, Tim Henman became the first player to be disqualified from Wimbledon in the Open era after hitting a ball in anger which struck a ball girl. More recently, Denis Shapovalov hit chair umpire Arnaud Gabas in the eye with a ball he struck in anger after losing his serve to Great Britain’s Kyle Edmund during a Davis Cup match in 2017. Although it was clear that Shapovalov did not intend to hit Gabas, referee Brian Earley declared an immediate default of Shapovalov for unsportsmanlike conduct.Footnote 29 More recently still, Novak Djokovic was disqualified from the 2020 US Open in similar circumstances after unintentionally hitting a line judge with a tennis ball. In each of these cases, the players were deemed to have engaged in ‘unsportsmanlike conduct’ and were defaulted from their respective matches.
‘Abuse of racquet or equipment’ is defined in the Code as ‘intentionally and violently destroying or damaging racquets or equipment or intentionally and violently hitting the net, court, umpire’s chair, or other fixture during a match out of anger or frustration’. Violations of this aspect of the Code are punished relatively frequently. Malis and Michalica describe the application of this rule as ‘clear’, and set out the purpose of it: ‘The purpose of this rule is to emphasize the historical legacy of this game and its ethos, which includes subtle non-aggressive manifestations, and therefore deliberately smashing things such as rackets is a social offense against good morals. The purpose of the rule is to sanction inappropriate behavior on the court.’Footnote 30 The approach is seemingly approved by sponsors. In 2017, racquet manufacturer Yonex reportedly inserted clauses into the contracts that it held with players using its equipment, meaning that the players would incur a financial penalty for abusing Yonex racquets. The move was to allow Yonex to maintain a ‘clean image’.Footnote 31
The examples given above illustrate potentially serious breaches of the Code, and some even resulted in physical harm to the victim. Although there are rare occasions in tennis where frustration or aggression do result in violence, the offences contained in the Code are not primarily concerned with keeping the players (or indeed officials, spectators or anybody else in close proximity) physically ‘safe’. The violence exhibited in each of these incidents constituted an egregious breach of the Code, not just because of the minor danger posed to the respective victims, but also because it violated the norms of the sport’s aesthetics.
This percolates through all levels of tennis, as Lake discovered in his auto-ethnographic study of a suburban London tennis club. What Lake refers to as ‘[t]he club’s code of behavioural etiquette’ encouraged members to adopt behaviours in keeping with the spirit of tennis, and to avoid overt displays of aggression. Lake ties these expectations to the traditions born of the historical development of the sport: ‘These standards rooted in history were cherished to protect tennis from unsavoury influences like over-aggression, petulance and dishonesty … deferential treatment was expected from those lower in the social hierarchy, and signs of disrespect or ignorance to these behavioural standards were felt as collective assaults on the club’s established value-system.’Footnote 32 As Lake makes clear in the excerpt above, the transgressions can be physical, but they can also manifest in other ways, such as verbally or through gestures or other actions.
2.1.2 Audible Obscenity, Visible Obscenity and Verbal Abuse
The offences of ‘audible obscenity’, ‘visible obscenity’ and verbal abuse’ seek to minimise the verbal and psychological forms of violence that Guilbert describes as common features of tennis.Footnote 33 When it comes to obscenity, the offences proscribe the use of ‘profane’ language and obscene gestures. As noted above, this is often self-directed, and a result of frustration,Footnote 34 with players seemingly unable to restrain themselves.Footnote 35 Since the offence of ‘audible obscenity’ covers ‘the use of words commonly known and understood to be profane and uttered clearly and loudly enough to be heard by the Court Officials or spectators’, those willing to be creative with their swearing may escape punishment. This has caused some controversy, insofar as it privileges those who do not speak English or use well-known expletives from other languages.Footnote 36
The offence of ‘verbal abuse’ makes it clear that it is not just particular words that will invite a Code violation, but the way in which they are directed at somebody. One of the most notorious examples of a player being punished for this type of behaviour occurred during a third-round match at Wimbledon in 1995 between Jeff Tarango and Alexander Mronz. Tarango was given a Code violation for ‘audible obscenity’ by the chair umpire Rebeuh after he told the crowd to ‘shut up’. Tarango challenged Rebeuh over whether this was sufficient to amount to ‘obscenity’ and asked for the supervisor to attend. The supervisor did attend, but did not overturn the Code violation warning. When Rebeuh sought to resume play, Tarango refused, shouting at the umpire: ‘You are the most corrupt official in the game, and you can’t do this.’ This earned Tarango a further Code violation for ‘verbal abuse’, at which point Tarango ‘threw a pair of tennis balls to the ground, grabbed his bag and became the first player in Wimbledon history to walk out in the middle of the game’.Footnote 37 Leaving the court without permission meant that Tarango was defaulted.Footnote 38 In what was the most surprising and shocking aspect of the episode, Tarango’s wife Benedicte Tarango came onto the court and slapped Rebeuh twice across the face.
3 Indiscipline and the Rising Popularity and Commercial Success of Tennis
Two observations should be made about the misconduct of Jeff Tarango described above. First, it was out of character; he had not received a Code violation before the events described above, and he never did in his subsequent tennis career. Second, it came at or towards the end of the high point of bad behaviour in tennis. In the 1970s and 1980s, tennis had witnessed the outspoken and iconoclastic antics of players such as John McEnroe, Jimmy Connors and Ilie Năstase. Lake notes that these three players, whom he refers to as the ‘bad boys’ of tennis, were also apt to be crowd favourites, and thus an inevitable crowd draw.Footnote 39 The increasing popularity of tennis brought commercial opportunities, and what Lake refers to as ‘the commodification of “bad boy” tennis’ was at least partly responsible for the increasing popularity of the sport in the 1970s and 1980s.Footnote 40
3.1 The Influence of Sponsors
The increased popularity of tennis made it commercially attractive, and the amount of money in tennis has increased markedly in the Open era. The relative wealth enjoyed by modern tennis comes principally from sponsors and the sale of broadcast rights, and the sums involved are significant. For instance, the sponsorship deal entered into by the Australian Open with its principal sponsor, Kia, is worth AU$107 million in the five years up to 2028 (Kia has been the main sponsor of the Open since 2002).Footnote 41 In addition, in November 2022, the Open signed a $500 million, five-year broadcasting deal with the Australian broadcaster Nine, covering broadcast rights from 2025 until 2029.Footnote 42
Sponsors engage with tennis (and other sports) because of a perceived alignment between their brand and the sport,Footnote 43 and in the belief that it will positively affect their business. Research shows that bad behaviour and ill-discipline on the part of athletes can harm the interests of sponsors;Footnote 44 the move by the manufacturer to penalise players who smash Yonex racquets reflects this concern. Yonex did not comment publicly on its decision, and it is rare for sponsors to issue public statements about concerns within a sport. However, there have been other instances where misconduct has clearly affected sponsorship arrangements in tennis. For example, major sponsors Nike and Tag Heuer cut ties with tennis player Maria Sharapova (at the time the world’s highest paid female athlete) when she admitted testing positive to the banned drug meldonium in 2016.Footnote 45 Misconduct can also affect the sponsorship of sports organisations: after unruly behaviour by the US team in the Davis Cup final against Sweden in 1984, sponsor Louisiana-Pacific Corporation threatened to withdraw its support unless the US Tennis Association put in place a code of conduct.Footnote 46 A contemporary newspaper reported the principal concern of this development: ‘Rule One is that they must “act with courtesy and civility towards competitors, officials and spectators”.’Footnote 47
There is a tension here. Governing bodies and sponsors purport to desire sport that is free from indiscipline in all its many forms, but sport must be engaging in order to appeal to its audience. As the experience of tennis in the 1970s and 1980s suggests, some forms of indiscipline may add to the allure of a sport and heighten its value as entertainment. Writing of the appeal of aggression and violence in sport, including tennis, Bryant, Zillmann and Raney state: ‘The extant evidence clearly indicates that increased player aggressiveness enhances spectators’, especially male spectators’, enjoyment of watching sports contests … and … commentary that stress[es] hostility and animosity between opponents can cause spectators to perceive play as more violent than it is and also can result in greater enjoyment for spectators.’Footnote 48 During a particularly tempestuous second-round match between John McEnroe and Ilie Năstase at the US Open in 1979, chair umpire Frank Hammond defaulted Năstase and awarded the match to McEnroe after issuing numerous warnings to Năstase for delaying play. The resultant crowd disturbance was later described by Năstase as ‘total chaos’ and led to the police being called.Footnote 49 In order to quell the discontent, tournament director Bill Talbert and tournament referee Mike Blanchard removed Hammond as umpire, with Blanchard taking his place in the chair. Blanchard revoked the default and reinstated Năstase, and the match was allowed to continue.Footnote 50 The lesson that McEnroe learned was clear; as he wrote in his autobiography: ‘the rules of tennis are eternally flexible and … promoters generally were loath to spoil a crackling good show by booting a crowd-pleasing marquee name’.Footnote 51
4 Adjudication and Enforcement
Reinstating Năstase was an egregious example, but it illustrates the point that adjudication and enforcement of the Code can be as important as its substantive contents.Footnote 52 Studies have suggested that ‘home advantage’ could contribute to inconsistent decision-making by tennis officials,Footnote 53 and this potential for bias extends to disciplinary matters.Footnote 54 As I have written elsewhere, popular opinion and media representations of players may influence the disciplinary action taken in relation to certain players:
[T]he governing body is likely to be sensitive to popular opinion, as viewed through the lens of media characterisations and representations, which can be a significant spur to decisive action. This may lead to calls for greater punishment, including on the basis of a participant’s past conduct and reputation. A recent comparison between the relative treatment of Australian professional players Nick Kyrgios and Daria Gavrilova suggested that ‘crowd favourite’ Gavrilova received considerably less opprobrium than Kyrgios for more serious disciplinary infractions.Footnote 55
The significance of enforcement practices independent from the substantive rules has importance beyond any implicit bias on the part of the officials. Some of the Rules of Tennis are routinely broken without any consequence for the offending players. For instance, a study of Grand Slam matches by Kolbinger, Großmann and Lames found that time rule violations occurred in relation to 58.5 per cent of serves (i.e. beyond the 20 seconds permitted between points), with only 0.1 per cent of these violations penalised by the umpire.Footnote 56
As long as it is applied consistently, this deviation from the law on the books is unlikely to prove controversial. But the appropriateness of ‘temporal variance’ in sport, whereby different rules are enforced in different ways at different points in a match, is more divisive. Berman discusses temporal variance in the application of the ‘foot fault’ rule in the 2009 US Open semi-final match between Serena Williams and Kim Clijsters. In this match, Williams was penalised for a foot fault by stepping over the baseline when serving. In arguing with the chair umpire about this, Williams was given a Code violation which ultimately resulted in her losing the match. For Berman, a minor infraction such as a foot fault should not be called at crucial points in a tennis match.Footnote 57 For Standen, however, this variance in the enforcement of the rules is never appropriate.Footnote 58
5 The Case of Grunting
The practice and treatment of ‘grunting’ in tennis has also proven a controversial topic in recent decades. Aside from often-expressed aesthetic objections to grunting, there are legitimate sporting reasons to be concerned about the practice. Although some studies point to grunting as a useful – even necessary – technique in tennis,Footnote 59 other research shows that it could affect the opponent’s anticipation of the ball trajectory, and that this could confer an unfair competitive advantage over the opponent.Footnote 60 This is potentially contrary to Rule 26 of the Rules of Tennis, which provides: ‘If a player is hindered in playing the point by a deliberate act of the opponent(s), the player shall win the point’, going on to say that an unintentional hindrance will result in a replay of the point. In addition to potentially being captured under the Rules of Tennis, grunting could also fall foul of Article IV(L) of the Code, as an example of ‘unsportsmanlike conduct’.
Grunting has been happening in tennis since at least the 1970s, with Jimmy Connors a noted practitioner, but it became something of a ‘moral panic’ when young female players like Monica Seles started grunting in the late 1980s. The noises made by Seles during her 1992 Wimbledon semi-final win over Martina Navratilova led to complaints from her opponent and negative media coverage for Seles,Footnote 61 and prompted a newspaper report that read: ‘Few would deny that the sound of Seles is one of the least aesthetic features of the sport. Though far removed from John McEnroe’s obscenities, Seles’s constant stream of exclamations, a cross between ‘Je t’aime’ and Tarzan, is offensive to the ears of spectators and opponents alike.’Footnote 62 For many, this juxtaposition of sexualisation (the reference to the Serge Gainsbourg and Jane Birkin song ‘Je t’aime’) and masculinisation (the reference to Tarzan) illustrates the gendered and sexist nature of the debate about grunting in tennis. Stahl suggests that ‘efforts to police the sound reinscribe weakness onto femininity’, and that this ‘weakens her performance for the pleasure of the spectators and the neutralization of a competitive advantage’.Footnote 63
Grunting continues to be a point of contention. During Wimbledon in 2009, the loud grunts of Portuguese player Michelle Larcher de Brito drew attention and complaints from both spectators and opponents. Although there was significant discussion about the possibility of implementing measures to control excessive grunting, Larcher de Brito was not formally penalised for her grunting.Footnote 64 Three years later, the WTA announced that it was working with the Grand Slam tournaments and the ITF to ‘drive excessive grunting out of tennis’.Footnote 65 Despite considerable attention devoted to the subject, and the potential to use both the Rules of Tennis and the Code to combat it, no prominent player has been disciplined for grunting. There are no records of the hindrance rule being used as a response, nor are there any recorded instances of a player being given a Code violation for grunting.
6 Changes to the Rules
As Lumer notes, sports’ rules and their enforcement are constantly evolving to meet the expectations of players and others: ‘The rules of the various sports games are reformed constantly in practice … or formally by the respective sports association. Usually, the reason for such reforms is raising social or moral desirability of the games: to make them more exciting or to adapt them to the individual preferences.’Footnote 66 Given its adherence to tradition, it is perhaps unsurprising that rule changes in tennis are a relative rarity, but developments in relation to on-court coaching and the Wimbledon dress code are recent standout examples where amendments have been made.
6.1 Coaching
Tennis is unusual in strictly limiting player–coach interaction during a match. In the football codes, for example, the coach, or indeed the whole coaching staff, can often be seen shouting instructions to the players during play. In tennis, however, the coach has been a more or less silent observer. The reasons for the restrictions are ostensibly competition-based; Malis and Michalica explain: ‘Tennis is an individual sport, and the fact that coaching during a match is forbidden increases the pressure on the player themselves, thereby supporting the individual philosophy of the sport.’Footnote 67 Permitting coaching during play arguably impinges on the individuality of the sport and introduces the possibility of unfairness; the availability of on-court coaching would deleteriously affect those lower-ranked players who cannot afford to have a coach present at their matches.
The extent of on-court coaching in tennis is unclear, but it was widely believed to be common practice at all levels of the sport.Footnote 68 In the wake of Serena Williams receiving a warning during her fourth-round match against Naomi Osaka at the US Open in 2018, Williams’s coach Patrick Mouratoglou suggested that the practice was ubiquitous. He stated that Osaka’s coach Sascha Bajin had been coaching Osaka during the same match (a claim denied by Bajin).Footnote 69 If this is true, and on-court coaching was ubiquitous, it was relatively rarely punished at the highest level: for instance, in 2018, ‘a total of 22 code violations for coaching were awarded at all four Grand Slams’.Footnote 70 Because of its seeming prevalence and the relative infrequency with which it was detected or punished, the banned practice posed a problem in relation to detection and enforcement.
The rules around coaching have been relaxed in recent years, with a trial taking place from 2020 on the WTA Tour and from 2022 on the ATP Tour. Players and coaches have offered a range of opinions on the changes.Footnote 71 Some years before the advent of the trials, Mouratoglou suggested that the officially proscribed practice is endemic and that lifting the ban would help to popularise the sport, stating: ‘Seeing and hearing the coaches and players talking to each other personalises the sport and brings out their characters.’Footnote 72 For Malis and Michalica, the relaxation of the rules was a necessary change: ‘We believe that the change in coaching rules that the WTA has made in 2022 is a step in the right direction (ATP Tour 2022). It is a departure from the individual philosophy of the sport, but we do not see a better solution under the circumstances.’Footnote 73
6.2 Wimbledon
Another recent change to the Code (as it applies in its amended form to the Wimbledon tournamentFootnote 74) relates to the famously strict clothing requirements that pertain to those participating at Wimbledon. Wimbledon has a reputation as the most conservative of the major tennis tournaments, possessing a ‘stuffiness’ that led to Andre Agassi refusing to play at the tournament in the late 1980s.Footnote 75 Central to its traditional aesthetic has been its insistence on all-white playing attire,Footnote 76 and numerous players have fallen foul of the dress code requirements. For instance, in 2017, Venus Williams was reportedly asked to change her pink bra after it became visible under her white top during play.Footnote 77 In 2023, however, Wimbledon introduced a significant change to its dress code, allowing female players to wear dark-coloured undershorts beneath their all-white outfits. This change was undertaken to address concerns about competing while menstruating.Footnote 78
6.3 Changes in Adjudication and Enforcement Practices
The changes to the coaching rules and the Wimbledon dress code are relatively rare examples of substantive rule changes. More subtle, but no less important, are shifts in the interpretation and enforcement of the written rules. To pick two examples in the realm of tennis, there have been observable changes in relation to race and mental health. These are areas in which the approach of the tennis authorities has clearly been affected by changing social mores, and perhaps with an eye on the views and desires of the sponsors.
6.3.1 Race
Tennis has largely moved past the overt racism experienced by black players such as Althea Gibson and Arthur Ashe.Footnote 79 However, opinions are divided on the extent to which positive change has been achieved. Leppard describes sport as essentially a ‘white space’; he states that ‘[t]he punitive treatment of black players in the world of sports demonstrates the continuation of racism albeit less overt’.Footnote 80 Leppard asserts that ‘athletes of colour like Venus and Serena Williams have continued to face racism throughout their careers which highlights that the world of tennis remains a white space despite the work of trailblazers’.Footnote 81
Tredway offers a similarly trenchant account of the racism faced by players such as Serena Williams, and offers an account of how this colours how she is perceived:
Serena is very successful in a sport that is underpinned by the upper-class and white milieu in which it was formed. Her outbursts have been understood in the popular discourse as violent not because they were more vehement than others, because they were not, but … because Serena has been positioned differently in women’s tennis, both historically and currently, than her White counterparts. These outbursts trigger a heightened perception of violence as compared to similar outbursts by White tennis players because Serena is not viewed as possibly the greatest tennis player to have ever played the sport, but as a Black woman and Black women are perceived to be violent.Footnote 82
For Tredway, this has had real implications for how the rules are interpreted and enforced when it comes to Williams’s conduct:
The rules, however, have not been regularly interpreted for other players in the ways that they were interpreted for Serena, if ever. In this sense, Serena is forced to play competitive tennis by different rules (because the rules are interpreted differently for her) than others in women’s tennis. Her outbursts are how she highlights this rift in the disciplinary domain of the matrix of domination, as anyone would who was treated unfairly. What, then, is different about Serena in the world of women’s tennis? It seems too obvious to state that it is her race; however, that is the primary difference between Serena and the other players.Footnote 83
As the pre-eminent female player of her generation, Serena Williams has clearly had a significant impact on tennis, and it is arguable that this is comparable to the male players of the 1970s and 1980s in the way that she has changed perceptions about the women’s game, and the place of women of colour in tennis. Malis and Michalica point to the contrasting treatment of Serena Williams in the 2009 and 2018 US Open as evidence that the tennis authorities are ‘influenced by American society’s greater sensitivity to gender issues’ and point to this as having a direct and positive effect on the operation of the rules.Footnote 84
Tredway argues that the Williams sisters have ‘normalised’ a previously incongruent ‘Black aesthetic and performance’ that has paved the way for others to follow;Footnote 85 she points to players like Madison Keys, Coco Gauffe and Taylor Townsend as benefitting from, and continuing, this.
6.3.2 Mental Health
The experiences of Naomi Osaka also illustrate developments in the relationships between players, tournament organisers and spectators. Osaka sees herself as an activist advocating for change as a woman of colour on the tour,Footnote 86 but she has also been at the forefront of mental health awareness. At the 2021 French Open, Osaka declared that she would not be engaging with the media during the tournament, claiming that the interactions were deleterious to her mental health. Osaka then refused to attend the post-match press conference after her first-round victory over Patricia Maria Tig. The French Tennis Federation fined Osaka US$15,000 and threatened her with expulsion. This was later compounded by threats of further fines and expulsion from other Grand Slam tournaments.Footnote 87 After Osaka withdrew from the event, she was met with messages of support from her national federation, major sponsors and high-profile figures within and outside of tennis.Footnote 88
The negative reaction to their punitive approach seemingly led to significant backtracking on the part of the tennis authorities, with statements issued on behalf of the four Grand Slam tournaments offering ‘support and assistance’ to Osaka.Footnote 89 Although her experience was not explicitly cited as inspiration, in 2023, Roland-Garros implemented an ‘anti-online harassment and hate speech tool’. This measure used artificial intelligence software to protect players from online abuse, and its implementation tacitly acknowledged the obligations of the tennis authorities amid a shifting understanding, appreciation and prioritisation of mental well-being.Footnote 90
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