Six Nations law discussion: The Paolo Garbisi moment that falls between the cracks

Paolo Garbisi in action for Italy.
It’s become a feature of touch-finding kicks, as kickers get progressively better at landing the ball on a penny from 50 metres, that the exit point of said kicks is getting closer and closer to the touchline.
It is also a feature then, of said kicks, that occasionally an enthusiastic winger or full-back might decide to perform a little acrobatics to keep the ball in play.
This usually happens one of two ways. Either he catches the ball off-balance and with the ball beyond the touchline but with his feet still in play, and then manages to direct the ball backwards and into the field of play before falling outside the touchline. Such as here:
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Meanwhile here about eight seconds in is another way: the player stands outside the field of play, but leaps into the air and flicks the ball in mid-air back into the field of play:
And then there’s moments such as this when a player leaps out of play but flicks the ball back in mid-air before landing outside of the field of play:
But on Saturday in the Six Nations, Italy’s Paolo Garbisi thought he had managed a similar piece of skill. He was standing outside the pitch, but he jumped into the air and flicked the ball backwards into the field of play while in mid-air. Yet this time referee Angus Gardner brought the teams back for a line-out. Why?
A quick look at the relevant legal paragraphs first:
Law 18: Touch or touch-in-goal
The ball is in touch or touch-in-goal when:
The ball or ball-carrier touches the touchline, touch-in-goal line or anything beyond.
A player, who is already touching the touchline, touch-in-goal line or anything beyond, catches or holds the ball.
If the ball has reached the plane of touch when it is caught, the catcher is not deemed to have taken the ball into touch.
If the ball has not reached the plane of touch when it is caught or picked up, the catcher is deemed to have taken the ball into touch, regardless of whether the ball was in motion or stationary.
The ball is not in touch or touch-in-goal if:
The ball reaches the plane of touch but is caught, knocked or kicked by a player who is in the playing area.
A player jumps, from within or outside the playing area, and catches the ball, and then lands in the playing area, regardless of whether the ball reached the plane of touch.
A player jumps from the playing area and knocks (or catches and releases) the ball back into the playing area, before landing in touch or touch-in-goal, regardless of whether the ball reached the plane of touch.
A player, who is in touch, kicks or knocks the ball, but does not hold it, provided it has not reached the plane of touch.
At first glance live, Garbisi appeared to have saved the ball from touch. But referee Gardner was quick to spot that although Garbisi had jumped and played the ball mid-air, he had jumped from outside the field of play and landed outside the field of play.
It was a difficult one to understand at the time, as the laws covering what is in touch do not explicitly cover this scenario, while the laws covering what is not in touch also do not explicitly cover this scenario. So Garbisi did not explicitly contravene any law.
However, he did not completely fulfil the conditions of Law 18.2.b, in that he, having jumped from outside the playing area, did not then land inside the playing area. So the ball is treated as though Garbisi touched the ball outside the playing area: i.e. the throw-in is given to the receiving team if the kick is an exit, or to the kicking team if it is a penalty.
It was good of Mr. Gardner to explain his decision so succinctly, but it would be helpful if there were an extra paragraph in the laws clarifying this aspect, as these sorts of plays are becoming more and more common.
READ MORE: Chris Robshaw’s Six Nations Team of the Week: Ben Earl the standout but Italy’s super six dominate