48.1 Illegal Check to the Head – A hit resulting in contact with an opponent’s head where the head was the main point of contact and such contact to the head was avoidable is not permitted. In determining whether contact with an opponent's head was avoidable, the circumstances of the hit including the following shall be considered:
- (i) Whether the player attempted to hit squarely through the opponent’s body and the head was not "picked" as a result of poor timing, poor angle of approach, or unnecessary extension of the body upward or outward.
- (ii) Whether the opponent put himself in a vulnerable position by assuming a posture that made head contact on an otherwise full body check unavoidable.
- (iii) Whether the opponent materially changed the position of his body or head immediately prior to or simultaneously with the hit in a way that significantly contributed to the head contact.
48.2 Minor Penalty – For violation of this rule, a minor penalty shall be assessed.
48.3 Major Penalty – There is no provision for a major penalty for this rule.
48.4 Game Misconduct Penalty – There is no provision for a game misconduct for this rule.
48.5 Match Penalty- "The Referee, at his discretion, may assess a match penalty if, in his judgment, the player attempted to or deliberately injured his opponent with an illegal check to the head"
By penalizing for check to the head, the refs essentially locked themselves into a minor or match penalty situation. Based on the force of the contact and the injury sustained by the Devils player, they basically had to call it a match. Would've been a similar situation if they called it charging though tbh, given rule 42.5
42.5 Game Misconduct Penalty - When a major penalty is imposed under this rule for an infraction resulting in an injury to the face or head of an opponent, a game misconduct shall be imposed.