The NRL's most-punished team lost the penalty count 6-2 in the second half and 11-6 overall in their 16-13 loss to the Sharks at Toyota Stadium on Saturday night.

In their 30-18 victory over Penrith the previous week, Newcastle were on the wrong end of Gavin Badger's 10-4 penalty count, which blew out to 10-1 early in the second half.

Knights coach Brian Smith refrained from criticising referee Tony Archer after the Cronulla loss, but Burraston unloaded yesterday on all whistle-blowers and will lodge a formal complaint this week with NRL referees coach Robert Finch.

"I think referees have a pre-conceived idea that we're an undisciplined club and we give a lot of penalties away, and they look for every minor thing that they can possibly penalise us on," Burraston said.

"We've done it through the right channels and it's not working, so I've got to start speaking out. We're working very hard as a club and as a team to get our penalty rate down.

"Whilst I don't believe we ever get a 50-50 call . . . it's the other team that concerns me. When they play us, they're almost perfect, but that doesn't happen in any other week against other teams.

"For a number of weeks now, we've made inquiries and complaints through the proper channels and I'm just not satisfied with what's coming back or what I'm seeing in games."

Insisting the Knights were not being victimised, Finch said he had spoken briefly with colleague Mick Stone about the Knights-Sharks game but would not formally review it until today and, therefore, would not comment specifically about incidents in that match.

But he said the NRL had provided regular feedback to the Knights about the number of mandatory penalties they had conceded this year and the club had not mended their ways.

"The bottom line of it all is that they were the second heaviest penalised side in the NRL as of last week," Finch said.

"The feedback from last week [against Penrith] was when you kick the ball out on the full, tackle a bloke in the air when he hasn't even got the ball, clean a kicker up after he kicks it, you're off-side in general play, they're all mandatory penalties.

"I think there were five of those in the first half last week, and I've been talking to Newcastle about mandatory penalties for a long time.

"Referees are certainly not going in with any pre-conceives, they only referee what they see, and if a player's off-side or if there's a mandatory issue that needs to be dealt with, they penalise. There's no rocket science behind any of this."

Burraston was especially aggrieved about a ruck penalty against five-eighth Chris Bailey in the 58th minute of Saturday's game. From that infringement, Sharks winger Luke Covell kicked the go-ahead goal for a 14-13 lead.

Standing at marker after tackling Brett Seymour, Bailey was adamant he was dragged down by the Cronulla pivot and indeed should have received the penalty.

"All I did was get to my feet and as I did, he's pulled my leg out and that's a penalty to us every day of the week, I think, but obviously not," Bailey said.

"It seems like every call like that is going against us at the moment, but I suppose we can't use that as an excuse . . . We had our opportunities and that's what's so disappointing."

Archer spoke to Kurt Gidley several times during the game, but Newcastle's stand-in skipper was not satisfied with the explanations.

"That was one of the most frustrating games I've been in," Gidley said.

"I didn't know what I could say to him. We just couldn't get anything. The ones in the play-the-ball where blokes lose the ball, our blokes don't deliberately try to do that sort of thing and it's just very hard to take."

Covell kicked another penalty goal in the 79th minute after Zeb Taia's high tackle on Sharks winger Misi Taulapapa was detected by video referee Paul Simpkins.