Should an NRL match have 20 penalties or four penalties?

Newcastle coach Brian Smith says the league should make up its mind.

"It's hard to know," he said after the Knights' gutsy 13-12 win over high-flying Gold Coast.

"We're going from some games where we've had massive, like I think we had 20 penalties in a game.

"And then tonight it was pretty obvious I thought that either the referee had instruction or he sort of seemed to have an attitude that there wasn't going to be a lot of penalties.

"That's good but it would be great if we all knew that that's how it was going to be all the time."

Referee Gavin Badger awarded only eight penalties during Saturday night's absorbing tussle at EnergyAustralia Stadium for a 4-4 count.

Out at Penrith, whistle-blower Ben Cummins was struck in the head by a missile from the crowd at fulltime - despite the Panthers winning a big penalty count 10-4.

"In the days where you could talk to a referee, as a coach I found myself standing in the tunnel next to the ref as we were waiting for the players to come back out," Smith said.

"(We) had a bit of a casual conversation - I thought it was casual anyway - and I told him that all week at training we've been practising this tap ... and I told him in intricate detail about how good a tap move this was.

"And he looked at me and eventually he said: `Well, what are you telling me for?'

"I said: `Well there's no chance of us getting the tap on in this game to show everyone if you don't give us a (pause) penalty'.

"I was starting to wonder again tonight for a while in the second half if it was going to get like that again."

Titans coach John Cartwright said the lack of penalties at the ruck Saturday night shackled two teams who like to play a free-flowing brand of football.

"The game to me seemed like a real wrestle-athon at the play-the-ball," he said.

Retired refereeing legend Bill Harrigan made controlling a game with minimal penalties his trademark, but Smith said he'd just like a ruling on what his side could expect each week.

"If we all knew we were all going to have two or three or four penalties in a game, if that was the way we were going to look at the game, well let me tell you we wouldn't practice those fancy taps that I was talking about," he said.

"You'd work on something else."

"In the golden days the Magpies used to come out and try to give 10 penalties away.

"At one stage Souths were like that in the 80s and Ronny Willey was coaching, they'd come out and rip everyone's heads off and do all that stuff that was aggressive.

"(Now) everyone's trying hard not to give penalties away."

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