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@Buffalo_Bill
Hard to say from a still. If the guy in the foreground has ridden into the arm which is already extended, it's a different thing to if the guy has come along side, and the arm has been extended to impede his progress, in which case I would call it as a holding penalty, as the arm is being used to hold the foreground player back.
It's possible that the foreground guy has ineptly attempted a blind-side check, from which the back ground guy is protecting himself. In this case, the foreground guy could be called for a blind-side check.
Depending on how the arm is used, you could call a fore-arm check on the background guy, which is not allowed under London Open 2012 rules, if the arm has been moved back across the rider, assuming they were going at the same speed, or the background guy was coming from behind.
I think it's very difficult to make a call based on a still, as the relative momentum & direction are difficult to read, and it's also impossible to tell what happened immediately before the incident shown, as there may have incidental contact, without any foul, from which both riders are trying to extricate themselves.
At the very least, if I was reffing, I would be very concerned to see how close the background guy's mallet is to the handle-bars of his opponent's bike.
And, just in case any readers are wondering, I have called all of the above fouls at various times in various tournaments (I called Manu for a blind-side check during the final or semi-final of London Open this year).