A palpably unfair act is loosely defined as an act by a player or team that far exceeds the bounds of sportsmanship, that the referee is empowered to make any equitable ruling necessary. It is a very rarely evoked provision of the rules.
Toledo at Dayton, October 13, 1951
Dayton, up 20-0 in the first quarter, lined up to kick the extra point after a 35-yard touchdown run. Toledo lineman Harry Lanzi jumped Dayton center Ed Clemens just before the snap and blocked the kick; referee Dan Tehan marked off the 1-yard half-the-distance offside penalty and Dayton lined up to kick from the Toledo 1. On the second attempt, Lanzi again jumped the center early and blocked the kick.
According to Tehan, recounting the event in 1959, “the rulebook at the time was not clear about what a referee could do when faced with intentional obstruction of an opponent’s opportunity to score. The closest it came was a statement that a referee should use his judgment in awarding a score or forfeiting a game.”
Tehan marked off the half-yard penalty and cautioned Lanzi. “Young fellow, you’re intentionally holding up the game. Once more and I’ll give Dayton the point.” Tehan added that “the Toledo player vocally challenged my authority to do so”; one can only wonder what Lanzi said, but no unsportsmanlike conduct flag was thrown.
On the third attempt, Lanzi once again went offside, and did so so early that Clemens never snapped the ball. True to his word, Tehan awarded one point to Dayton. (Dayton kicker Paul Spakowski was originally credited with a made extra point, but the NCAA later ruled that the point be credited to the Dayton team as a whole and not to any individual player.)
Dayton went on to win easily, 47-7.
(Note that the NCAA did not have the two-point conversion rule until 1958, so going for two or awarding two points weren’t options.)