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The NCAA rule doesn't require a "normal position" either, but it does require that it be obvious a scrimmage kick be made. I guess if you have a defender flying in for a tackle and a very quick kick, you might have a judgement call, but the rule also states that the "kicker and holder must be protected from injury." That tells me the committee wants non-incidental contact called unless there's a good and specific reason not to call it.
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