Carney wasn't provided the opportunity to front Cronulla's board, which is why Callinan's independent committee came up with their ruling, opening Carney up to financial compensation. While the unfair dismissal case is a victory for Carney, it won't automatically result in his return to the NRL.

The former Canberra, Roosters and Cronulla star, who scored 59 tries and 827 points in his 166-game NRL career, is in the first year of a three-year deal with English Super League club Catalans Dragons.

The NRL is also aware of the disrepute the vulgar photograph of Carney brought to the game, undertaking extensive research to discover the magnitude of the negative impact his misdemeanour had on the image of the NRL.

Fairfax Media understands any attempt from the Sea Eagles to register Carney's contract will be met with resistance from the NRL, especially given his history of repeated off-field discretions since making his debut at the Raiders in 2004. NRL head of football Todd Greenberg admitted any club interested in Carney's services would need to put forward a compelling case to convince the game's governing body he was fit to return.

"If clubs want to register contracts they have to put them up to the NRL and they'd have to provide a fit and proper person test to register a contract with the NRL," Greenberg said. "They are matters for our integrity unit and we'll have to look at those if and when they come to us."