Since September 2016, there have been 18 breaches of article 2.12 of the Code of Conduct, which deals with "inappropriate physical contact with a Player, Player Support Personnel, Umpire, Match Referee or any other person (including a spectator) during an International Match", except for the Kohli-Konstas incident. As for the 20 per cent match fees fine, among the 12 out of the 18 incidents where only one demerit point was handed out, a fine greater than what Kohli received has been given out only thrice - to George Munsey of Scotland, Farid Ahmed Malik of Afghanistan, and Jasdeep Singh of USA - all of whom were fined 25 per cent of their match fees for breaching article 2.12.