Some rivalries become so heated that the conventional confines of the ring cannot contain the hatred between opponents. Fans have seen feuds like these settled in Hell in a Cell, Strap matches, or even the conventional No Disqualification bout. But there are rare occasions in kayfabe, where the promotion itself distances itself from the rivalry and wants nothing to do with an impending match.
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These are Unsanctioned matches, where the promotion is not responsible for the fate of the wrestlers. It is an interesting wrinkle in a story that sells the blood feud. WWE’s most recent example of such a match is Kevin Owens vs. Sami Zayn at the 2025 Elimination Chamber PLE. WWE has resorted to this stipulation sparingly in the past, scattered across its vast history.
Shawn Michaels Vs. Triple H: SummerSlam 2002
This Was HBK’s First Match Since WrestleMania 14
- This was Shawn Michaels’s first match in four years.
- Triple H turned on Michaels after HBK refused to be his manager.
- Michaels showed no ring-rust and was incredible.
Despite retiring from in-ring competition in 1998, Shawn Michaels was a regular presence on WWE programming. He was involved in major storylines because the promotion benefitted from his presence. Between 1998 and 2002, Michaels hit rock bottom and began rebuilding his life by getting clean and finding religion. After Michaels refused to be Triple H’s manager at Raw General Manager Eric Bischoff’s behest, The Game turned on HBK.
Their fantastic feud blurred the line between kayfabe and reality, as both men had a real-life falling out because of Michaels’ addiction. This led to an Unsanctioned Match at SummerSlam 2002. Michaels was incredible in the bout. He seemed to have no ring rust and could push himself in the squared circle because of his real-life trust in Triple H. The violent, bloody encounter ended with Shawn Michaels winning with a roll-up. But Triple H struck him twice with a sledgehammer, incensed at his loss, leading to HBK being carried off in a stretcher.
Chris Jericho Vs. Shawn Michaels: Unforgiven 2008
Their Feud Was Filled With Bitter Hatred And Fury
- Chris Jericho threw Michaels face-first through a TV screen.
- At SummerSlam 2008, Michaels announced his retirement, but that changed after Jericho punched his wife in the face.
- Michaels destroyed Jericho at Unforgiven.
Six years after he feuded with Triple H, Shawn Michaels found himself in familiar territory once more, this time with Chris Jericho. In the lead-up to Unforgiven, Chris Jericho brutalized Michaels, throwing him face-first through a TV screen. The week after the attack, it was revealed that Michaels had a detached retina (for the story), which Jericho targeted in their bout at Great American Bash 2008.
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At SummerSlam, Michaels announced his in-ring retirement but was quick to change his mind after Chris Jericho punched his wife in the face. This led to their Unsanctioned match at Unforgiven, where Michaels gave Jericho a beating of a lifetime, forcing the referee to call off the bout and announce HBK the winner.
Randy Orton Vs. Shane McMahon: Monday Night Raw, Feb 16th, 2009
The Viper Was At His Peak, Tormenting The McMahon Family
- Randy Orton targeted the McMahon family in January 2009. He hit Mr. McMahon with a punt kick.
- Shane McMahon tried to avenge his family in a No Holds Barred match at No Way Out, but lost to Orton.
- The next night, McMahon lost to Orton again, this time in an Unsanctioned match. Orton hit Stephanie with an RKO, kickstarting his WrestleMania 25 feud with Triple H.
Randy Orton was at his villainous best in January 2009 when he began feuding with the McMahons. He declared himself better than Mr. McMahon and Stephanie, and punted the family patriarch before he could be fired. Just six days later, Orton won the Royal Rumble and then claimed he suffered from Intermittent Explosive Disorder (IED), to explain away his attack on Mr. McMahon. He also claimed WWE knew about the disorder and threatened a lawsuit if he was fired.
At this point, Stephanie McMahon brought out her brother Shane, who failed to beat Orton in a No Holds Barred Match at No Way Out. On next night’s Raw, the two were booked in an Unsanctioned match, which Orton won as well, after punting Shane to knock him out. After the match, he hit Stephanie McMahon with an RKO, which brought Triple H into the fold, setting up their title feud on the road to WrestleMania 25.
Seth Rollins Vs. Triple H: WrestleMania 33
Rollins Wanted Revenge After The Game Cost Him The Universal Championship
- Finn Balor was forced to vacate the Universal Championship the night after he won it due to injury.
- In a fatal four-way to determine a new champion, Triple H turned on Seth Rollins so Kevin Owens could win the title.
- Rollins felt betrayed, leading to an Unsanctioned match at WrestleMania 33 against Triple H, which Rollins won.
On the Raw after SummerSlam 2016, Finn Balor was forced to vacate the Universal Championship due to injury. In the main event, WWE booked a fatal four-way to determine a new champion. Seth Rollins competed against Big Cass, Roman Reigns, and Kevin Owens. Just as he was on the cusp of victory, Triple H hit him with a Pedigree, allowing Kevin Owens to become the new Universal Champion.
Rollins spent the rest of the year trying and failing to win the title due to a series of heel shenanigans. In January 2017, Rollins turned his attention to Triple H, demanding answers and retribution. They eventually faced off in an Unsanctioned match at WrestleMania 33, which Rollins won.
Johnny Gargano Vs. Tommaso Ciampa: NXT TakeOver: New Orleans 2018
This Was An Epic Match A Year In The Making
- Tommaso Ciampa turning on Johnny Gargano is one of the most shocking moments in NXT history.
- WWE had to put the feud on ice for some time because Ciampa needed surgery after injuring his ACL.
- Eventually, they wrestled an instant classic at NXT TakeOver: New Orleans in 2018, which Gargano won.
Tommaso Ciampa’s shocking heel turn on Johnny Gargano to end DIY at NXT TakeOver: Chicago 2017 is one of the greatest NXT moments ever. WWE had to put the feud on ice because of Ciampa’s torn ACL, which required surgery.
In early 2018, Ciampa returned to torment Gargano, leading to an Unsanctioned match at NXT TakeOver: New Orleans in April 2018. Both men put on one of the greatest matches in WWE history, full of drama, emotional beats, and incredible in-ring action. Gargano bested Ciampa in arguably the best performance of either man’s career.
Drake Maverick Vs. Mike Kanellis: 205 Live, July 30th, 2019
Both Men Were Driven To Rage By Their Main Roster Storylines
- Mike Kanellis repeatedly accused 205 Live General Manager Drake Maverick of using him improperly.
- Kanellis referenced Maverick’s marital issues because he was too focused on the 24/7 Championship. Kanellis believed he could save his own marriage by becoming Cruiserweight Champion.
- Kanellis pushed Maverick too far, leading to an Unsanctioned match with the GM won.
Drake Maverick and Mike Kanellis got embroiled in an extremely intense feud on 205 Live while being made fools of on the main roster. After joining 205 Live, Kanellis repeatedly accused General Manager Maverick of using him improperly. Things got heated when Kanellis made some unsavory comments about Maverick’s marital troubles because of his focus on the 24/7 Championship.
Kanellis believed that he could salvage his own marriage if he became Cruiserweight Champion, but he pushed Maverick too far. The GM decided that Kanellis would have to get through him to get a shot at the title, setting the stage for their Unsanctioned Match. Maverick and Kanellis put on excellent performances, with the former reminding everyone just how good he was in the ring when he put Kanellis away.
Randy Orton Vs. Big Show: Monday Night Raw, July 20th, 2020
Orton Found His Killer Instinct Once More And Was Targeting Legends
- Randy Orton’s feud with Edge in 2020 came to a halt after The Rated-R Superstar tore his triceps at Backlash.
- Orton resurrected the Legend Killer persona and attacked Christian and Shawn Michaels.
- In an Unsanctioned match against Big Show on Raw, Orton emerged victorious.
After losing to Edge in an overlong Last Man Standing match at WrestleMania 36, they were booked in a rematch at Backlash. Dubbed the “Greatest Wrestling Match Ever,” Orton put Edge away with the punt, a move he hadn’t used in years. Edge wound up on the shelf for several months due to torn triceps, prompting Orton to revive the Legend Killer within him.
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He brutalized Christian, attacked Shawn Michaels, and became increasingly unhinged. On the July 20th, 2020 episode of Raw, Orton was booked in an Unsanctioned match with another legend, Big Show. The giant dominated the early stages of the match, but once Orton took control, the outcome was without question. Orton beat Show with an RKO and then punted him in the side of the head for good measure.
Adam Cole Vs. Kyle O’Reilly: NXT TakeOver: Stand And Deliver 2021
This Was A Deeply Emotional Feud Triggered By The End Of The Undisputed Era
- Adam Cole fractured the Undisputed Era when he superkicked Kyle O’Reilly.
- They cost each other important matches and had several tense encounters.
- At Night 2 of NXT TakeOver: Stand and Deliver in 2021, O’Reilly defeated Cole in an Unsanctioned match.
Every NXT fan was heartbroken when Adam Cole ended the Undisputed Era at the end of NXT TakeOver: Vengeance Day, in February 2021. He superkicked Kyle O’Reilly, sparking a feud between both men. Cole interfered in O’Reilly’s matches, while O’Reilly ensured Cole would not win Finn Balor’s NXT Championship.
After several intense encounters, they agreed to face each other in an Unsanctioned match on Night 2 of NXT TakeOver: Stand and Deliver. The match ran over 40 minutes and strained credulity as both men repeatedly kicked out of signature moves. In the end, O’Reilly hit Cole with a low blow, and then a diving knee with a chain wrapped around it. O’Reilly emerged victorious but could barely stand, while Cole was stretchered away.
Grayson Waller Vs. Johnny Gargano: NXT: Stand And Deliver, 2023
Gargano Had A Bone To Pick With Waller For Ruining His Farewell
- Team Black & Gold lost to the rising Team 2.0 at NXT WarGargames 2021.
- Grayson Waller, a member of Team 2.0 attacked Johnny Gargano, a member of Team Black & Gold during his farewell.
- Two years later when Waller tried to goad Shawn Michaels into a match, Gargano returned to set up an Unsanctioned match at the 2023 Stand and Deliver. Gargano won, but Waller looked strong in defeat.
At the 2021 NXT WarGames, Team Black & Gold lost to Team 2.0, marking the end of the black and gold era. On the next episode of NXT, Johnny Gargano, one of the members of Team Black & Gold and the erstwhile heart of NXT, bade farewell. But before he could complete his goodbye, he was brutally attacked by a member of Team 2.0, Grayson Waller. Waller grew into a brash, smart-talking heel and, after he repeatedly failed to beat Bron Breakker for the NXT Championship, he invited Shawn Michaels to The Grayson Waller Effect.
On the show, Waller tried to convince Michaels to come out of retirement and wrestle him at NXT: Stand and Deliver on April 1st, 2023. Michaels declined the offer because he had someone else in mind, prompting Gargano’s return, which led to an Unsanctioned match at the event. Gargano beat Waller at Stand and Deliver, but the heel came out of it looking strong, even if he lost.
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