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1997 NHL Rulebook - Playing Rules Rule 72. Protection of Goalkeeper
NOTE: A goalkeeper is not "fair game" just because he is outside the goal crease area. A penalty for interference or
charging (minor or major) should be called in every case where an opposing player makes unnecessary contact with the
goalkeeper. Likewise, referees should be alert to penalize goalkeepers for tripping, slashing, or spearing in the vicinity of
the goal.
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