A case of reinstatement for Ajax’s ‘Three Little Birds’ – A counter to UEFA’s narrow interpretation of the Equipment Regulations

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[Author: Codanda Cariapa Chengappa, a student of law at Jindal Global Law School, India]

Let’s talk Sports Law S4_E9


One of the most powerful bonds of the sporting world is the connection between fans and their team culture. Over time, sports such as football have seen innumerable forms of expression being meted out by fans for their respective clubs and national teams. This bond is undoubtedly expressed in different ways with the underlying aspect of love for the Beautiful Game. Any legal regulation or a statute that obstructs such a bond is an injustice to football fans and must be countered in manners that are deemed appropriate as per the situation at hand. While UEFA cannot be discounted in its attempts to regulate forms of club expression, the benefit of doubt arising from such conflicts must be perused with the perspective of all parties involved in the functioning of a football club.

Ahead of the 2021-2022 season, Ajax came out with a third jersey in collaboration with Adidas. The kit was designed around the club anthem ‘Three Little Birds’(Bob Marley) that is sung before almost every home game at the Johan Cruijff Arena. The jersey included a sign representing three little birds that was placed at the back of the shirt under the collar. Quite specifically, the birds were colored red, yellow and green on a black background of the jersey. The ulterior message and intention behind making the jersey was to pay tribute to Bob Marley’s legacy that had been integrated into the club culture and strengthened on the same lines by the fans of Ajax. This song was first sung back in 2008 after a club friendly and was gradually integrated into a regularly featured song sung at all home games since then. This also included Bob Marley’s son performing once in 2018 for the Ajax fans.

UEFA came down heavily on the club and cited Article 7 and 19 of the UEFA Equipment Regulation  to justify that the bird sign was not a valid ‘club identification’. They subsequently directed that the ‘three little birds’ sign had to be removed from the shirt.

A fundamental issue that arises in this regard is the strict interpretation of regulations regarding club culture. At a time when football clubs have expanded their outreach focus to include varied forms of fan-based inclusion, ‘Three Little Birds’ goes a step further in enhancing Ajax’s team identity. This expansion includes racial, cultural, demographic, and even commercial expansion outreach in that is implemented keeping in mind the sentiments of fans. Ajax intended to pay tribute to their fans and Bob Marley by displaying a form of team identification that resonated with its club for a considerable period. By interpreting this move strictly and subsequently restricting it, UEFA has restricted an important aspect of freedom of club expression that must be innately vested with football clubs.

Time Stands with Ajax

Regarding time as a deciding factor of club identity, there is a reasonable inference since 2008 that ‘Three Little Birds’ has become a mainstay club anthem. It is officially sung by the ‘Ajax Ultras’ and has also been recognized by Bob Marley’s children as a fitting tribute to the Reggae star. ADIDAS partnered with Universal Music House who owned the rights to Bob Marley’s songs to come up with this concept. All the parties involved have made it a point to recognize the importance of Ajax’s relationship with Bob Marley and the spontaneous adoption of the song. This correlation and adoption of the song as a club anthem is a viable recognition as a form of club culture given that it is a permanent feature within essential functioning of the club.

This thereby debunks the primary argument made by UEFA that the Three Little Birds sign is not recognizable as a part of Ajax’s club culture.

Contradicting Decision

A definite contradiction to UEFA’s decision is the controversial Liverpool 2012 home jersey. After the 1989 Hillsborough disaster, Liverpool began showcasing two flames on their jersey and club crest as form of a tribute to those who lost their lives in the disaster. This continued between 1993 until 2012 when the two flames were moved to the backside of the jersey under the collar. This received a backlash from the Hillsborough Family Support Group who had genuine reasons for being aggrieved. However, what stood out was that UEFA did not comment on the change in the position of the flames. The two flames were formerly a part of the club emblem so their subsequent shifting and separation would not be deemed as a lack of team identification. Moreover, the Hillsborough disaster was a tragedy which Liverpool wished to conceptualize into a tribute and the separate flames were still considered as valid team identity.

Keeping the “unofficial precedent” of the Liverpool jersey in mind, we can infer the ‘Three Little Birds’ sign stands true to the identity of Ajax. Like the Hillsborough flames, the birds sign has come to represent a conceptualized tribute and identity. This cannot be taken away from the fans who have time and again reminded the world that football is a form of unity unlike any other, through their rendition of ‘Three Little Birds’. Moreover, Article 7(a) expressly states that “the collar area may only contain team identification”. Ajax have specifically utilized the collar area to express an identity established over time.


UEFA must consider amending Article 7(a) of the Equipment Regulations to allow teams the liberty of expressing what is close to their fans and culture. Quite specifically, since Article 7(a) is to be read with Article 19, clubs must be given the benefit of an expansive interpretation to put signs associated with club culture on the collar zone areas. To allow UEFA to have a say in the matter, clubs along with jersey manufactures should also provide adequate reasoning behind putting specific signs on their collar zone areas.   Unless there are serious moral and ethical violations, a club should be allowed to represent its traditions reasonably and in the most recognizable manner. Specific instances of regulation can be allowed wherein UEFA can be permitted to step in and regulate forms of expression based on subjective interpretations of situations. This mode of recourse stands on a better pedestal than an objective perspective that is sought to be achieved.

If UEFA truly believes in the mandated ideals and objectives of Article 1 of its General Provisions and the right of expression of fans, Ajax should have been permitted to wear its third jersey without any restrictions. At a time of great cultural and social intermixing,  football clubs stand at the forefront of protecting and promoting forms of expression in the 21st century.   This specific tribute undeniably is also to Bob Marley, a football fan who was an ardent lover of the Beautiful Game.

*For any query, feedback or discussion, the Author can be contacted at []

*NOTE- The opinions and views expressed in this article are that of the Author(s) and not of SLPRR- the expressed opinions do not, in any way whatsoever, reflect the views of any third party, including any institution/organization that the Author(s) is/are currently associated to or was/were associated to in the past. Furthermore, the expressions are solely for informational and educational purposes, and must not be deemed to constitute any kind of advice. The hyperlinks in this blog might take you to webpages operated by third parties- SLPRR does not guarantee or endorse the accuracy or reliability of any information, data, opinions, advice, statements, etc. on these webpages.

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