The Football Association are reviewing the comments Joe Kinnear made after Newcastle's 2-1 Barclays Premier League defeat against Fulham.
Kinnear branded official Martin Atkinson a "Mickey Mouse referee" for failing to spot a foul by Fulham's Andy Johnson on Claudio Cacapa in the build-up to the decisive penalty on Sunday.
The interim Newcastle manager accused Atkinson of costing his side at least a point, as they lost 2-1 at Craven Cottage and also criticised the general standards of refereeing. Kinnear may be asked to explain his outburst, with a decision on whether the FA intend to pursue the matter likely on Tuesday.
"There was a blatant foul prior to the penalty, which the referee ignored," Kinnear said. "We were camped in their half. Cacapa was on the ball - and Johnson completely pushes him out the way, nicks the ball and gets the penalty.
"We've got the Mickey Mouse referee doing nothing. He's made an error that cost us. That's the standard of refereeing in this country.
"It happens week in, week out. There's always a smart answer like 'someone was obstructing my view'.
"You used to be able to have a bit of banter with referees, and they'd put their hands up if they make mistakes. Now they hide."
It is not Kinnear's first spat with an official - he was given a two-match touchline ban in 2004 for calling referee Clive Penton 'Coco the Clown' while at Nottingham Forest.
The suspension meant he was unable to sit in the dug-out for Newcastle until mid-October, and there could be a similar conclusion to this latest incident.
Kinnear was incensed by the defeat, after claiming his side could have won given their dominance until Danny Murphy snatched all three points from the spot.
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