You would not want to underestimate Donna Shalala on a tennis court. Or in a poker game. Or in a boxing ring.

The NCAA has a nasty cut over its eye, and Shalala is pummeling it, making it bleed.

The University of Miami president is doing something unprecedented: She is fighting back.

Most of Shalala’s peers at universities in the United States would not dare challenge the NCAA in scathing public statements with a verdict pending.

But Shalala did so, right in the middle of a basketball game. After two years of bowing and cooperating and staying mum during the NCAA’s investigation of booster Nevin Shapiro’s slimy influence on UM football and basketball, Shalala has removed the kid gloves and put on the heavy ones.

During halftime of UM’s 54-50 win over Virginia on Tuesday, Shalala left her seat in the stands and went outside the arena to compose her rebuttal to the NCAA’s Notice of Allegations delivered earlier in the day.

She said the NCAA “violated its own policy,” called reliance on corroboration from convicted Ponzi-schemer Shapiro “ludicrous” and said UM has “suffered enough.”

Her strategy could backfire when the Committee on Infractions decides how to penalize UM. She knows that. But she’s ready to take the risk.

She should also be ready to reveal the charges against UM. After demanding and lauding the principle of transparency, she should practice it. Shalala’s indignation is valid — and strategic. But her school, under her watch, has been accused of “lack of institutional control,” the Doomsday Switch of NCAA accusations. If that is unfair or unsubstantiated, then show why.

The NCAA has been criticized as the “pot calling the kettle black” by botching its investigation of unethical behavior at UM with unethical behavior by its enforcement staff. UM can and should avoid similar criticism that it is being hypocritical in its reaction.

The NCAA is accustomed to being a punching bag. It’s easy to take shots at the organization that is perceived as the spoilsport of college sports. The NCAA is as unloved as the Internal Revenue Service. The NCAA is “always out to get us” say fans of UM or USC or Ohio State or [Fill in Blank], who seem to forget that the NCAA would not have any power unless its member institutions agreed to abide by their own rules. Said fans never want accusations against “their” teams investigated by the incompetent, petty NCAA but they do want the biased, corrupt NCAA to go after those cheating scoundrels at Florida or Auburn or Connecticut or [Fill in Blank].

Ironies abound in a system that has been flawed for decades. The outrage gets louder as the money gets bigger. College sports is a multi-billion-dollar industry that has become tougher to regulate. The Securities and Exchange Commission no longer has the resources to police Wall Street, either.

Shalala sees an opening. NCAA president Mark Emmert ordered an investigation of the investigation, and 20 percent of the evidence was discarded.

She would like to settle the whole thing, get credit for UM’s self-imposed postseason bans, player suspensions and reduced recruiting visits and call it a wash.

But Emmert isn’t backing down. He knows UM does not get to dictate its own punishment. Penn State didn’t. What if we could self-impose our own penalty after running a stop sign?