Quote: the wrestler "but why then is an arm to the head a penalty, when clashes of heads are not, as surely the same could be said of those?'"
Because in the context of a tackle the arms are relatively free to move in multiple directions/angles under control from the player when effecting a tackle, where those arms should be in relation to a players body can be easily controlled.
Then look at the head, it is fixed in place with a maximum of 6-8 inches sideways movement, it can be extremely hard to move the head out of the way when the momentum of your body is the main deciding factor in its trajectory. No-one tries to make a tackle with their head (it fecking hurts banging your head) nor have I seen anyone run in leading with their heads to make deliberate contact to another players head (okay not for over 25 years and then the player was a bit mental to say the least)
Those saying MM deliberately used his head against Sinfield are barking and I've yet to see anything but clear heabutts (when standing & not running in) as the only time contact to the head with another head should be a penalty.