Why Did Lord Glennie Find in Favour of Rangers in the Judicial Review against the SFA?

In which I go through Lord Glennie’s judgement and try to make sense of it.

The Herald has been kind enough to post the opinion of Lord Glennie in relation to Rangers’ “appeal” against the signing ban imposed by the SFA. Michael Grant’s article on it is here, and is worth a read.

You can see the full judgement here – Opinion of Lord Glennie in Petition of Rangers Football Club PLC for Judicial Review

I propose to go through it in some detail, and in a later post wrote about what might happen going forward. For clarity, the Judicial Panel (JP) is that chaired by Gary Allan QC which imposed the signing ban initially. The Appellate Tribunal (AT) was that chaired by Lord Carloway which upheld the decision. The relevant documents used in determining the decision were the Articles of Association of the SFA (Articles) and the Judicial Panel Protocol (JPP).

I would say is that, without the resources to have legally qualified, or at least legally attuned, reporters present throughout the hearing, it was always going to be difficult for the media to cover this case properly. The coverage there had been was confusing, and indeed one lawyer with whom I engaged on Twitter indicated that the disposal from the bench had not made especially clear what the precise decision was, other than Rangers had been successful in having the signing ban declared outwith the powers (“ultra vires”) of the JP. However, having sight of the decision makes all these matters crystal clear, and I hope not to muddy the waters in explaining it myself!

What was the Decision?

Put simply, Lord Glennie decided that, despite the arguments of Aidan O’Neill QC for the SFA, the JP did not, under the Articles of Association and JPP have the power to impose a signing ban. He therefore quashed that sanction.

He then decided to send the case back to the AT for reconsideration of the additional sanction, if any, to be imposed over and above the maximum fine for bringing the game into disrepute. Rangers were found entitled to the expenses of the application.

He could have instead quashed the full decision of the JP and sent the case back there. There were three reasons for not doing so.

1                     Speed – the AT could reconsider that part of the decision rather than requiring the JP to have a full hearing again regarding all the matters at issue, with the right again of a further appeal back to the AT;

2                     As the challenge only concerned the additional sanction, it was appropriate to let the AT decide this, as a quashing of the full decision would send the case back to the JP with all matters, including the question of guilt and the financial penalty again open for argument, even though they had already been accepted and not challenged by Rangers; and

3                     Under Rule 15.6.1.6 the AT can itself remit the case to the JP, and Lord Glennie felt that it was better to leave that decision to the AT itself, rather than impose it himself.

It needs to be said that, whilst the case was undoubtedly won by Rangers, in that the signing ban was quashed, their success was not complete. Richard Keen, QC, the Dean of the Faculty of Advocates, had urged Lord Glennie “simply” to quash the additional sanction. If this suggestion had been accepted, then the case would have been over, and the only penalty for bringing the game into disrepute would have been the fine.

Lord Glennie refused to follow this helpful suggestion and remitted the matter back to the AT. That he did so was entirely in accordance with the principle of Judicial Review. Put shortly, the purpose of Judicial Review is to see that decisions are made in accordance with the rules and that, within the wide legal definition, these are “reasonable”. The purpose of Judicial Review is not for the court to interfere by imposing the decision the court thinks right.  What the court thinks the correct decision to be is actually irrelevant. Lord Glennie noted that, if he did what Mr Keen urged, then the only penalty would be the £100,000 fine, which had been identified by both the JP and the AT as inadequate.

In this case, it was made clear by Mr Keen that this was NOT an appeal, but instead an application to the supervisory jurisdiction of the court, as the JP and AT had exceeded their jurisdiction. As Lord Glennie noted, “There is no appeal to this court on the merits of the case or concerning the appropriateness of the sanction if it was within the powers of the Tribunals.”

Therefore the decision to remit the case to the AT is entirely in accordance with the principles of Judicial Review. Indeed, for the court to have refused to do so and to impose its own decision would have been an acknowledgement that the AT was so tainted by its mistake to render it impossible for a fair decision to be given, or else that there could be no other decision by the AT than the one left after the court had quashed part of it.

That is why the case has been remitted to the same AT to deal with. Whilst Lord Carloway’s Tribunal has been decided to have fallen into error regarding its powers, it was not such an egregious mistake as to suggest bias or some other reason for removing the appellate power from it.

Did Lord Glennie Give the AT Any Directions?

Other than telling them that, for reasons I will come to, the AT could not impose a signing ban, and that it was restricted to the specific penalties mentioned in Rule of the JPP, he did not give the AT any directions. For a breach of Rule 66 (bringing the game into disrepute) the JP had the power to impose any of the following penalties, or a combination thereof:- a fine, suspension, ejection from the Scottish Cup, expulsion from participating in football and termination of membership of the SFA.

He commented that the JPP gave a range of sanctions, low level, mid level, top level and maximum. He noted that “in the present case the Tribunal thought that the conduct merited the maximum sanction and that is not challenged in this court.

He quoted the AT which had said, in commenting on the JP decision:-

“Although the AT agreed with the JP that termination, suspension of membership would have been excessive, it made that assessment in the context of the availability of competent lesser sanctions such as the one actually imposed. Ere that option not to have been available, suspension might have had to be considered appropriate for such serious misconduct which has brought the game into disrepute.”

Lord Glennie went on to say “The fact that I find the imposition of the additional sanctions to be ultra vires does not necessarily mean that the petitioners will escape to a lighter and ineffective punishment. That is entirely a matter for the Appeal Tribunal and not for this court.”

Why Did Lord Glennie Decide the Signing Ban was Ultra Vires?

What we saw was a good old piece of interpretation.

He viewed the issue as one of interpretation of a contract, as the Articles and JPP effectively form Rangers contract with the SFA.

It was agreed that the AT and the JP were “specialist” tribunals and therefore assumed to be looking not at what the outside observer or disinterested lawyer might make of the Articles or the JPP, but instead at what people involved in football meant by these documents.

Mr O’Neill sought to argue that the Articles should not be interpreted as if a contract, but instead as rules governing football in Scotland at all levels. He described it as being absurd if an over-rigid interpretation led to a way which prevented the JP from having sufficient powers top deal with a problem, or which required it to use disproportionate and excessive powers.

However, Mr O’Neill fell foul of the normal rule of interpretation which is that words are to be given their normal meaning, and outside sources of interpretation only arise where there is doubt about what the statement means. Here Lord Glennie did not see any such doubt.

His decision making process started at Article 94.1 which deals with the powers of the JP. It gives the JP powers to use against anyone who brings the game into disrepute. These are stated to be the penalties mentioned above and any other sanction as provided for in the JPP.

Article 95 states that the JP has the power to deal with any breach of the Articles by various means including the imposition of any sanction mentioned on the JPP. However Lord Glennie pointed out that Article 94 only gave powers to the JP in the event of a breach of the rules, and did not itself create an offence, and therefore Article 95, as founded on by the SFA, was irrelevant.

Article 94 gives the JP power to apply sanctions as per the JPP. Reference is made in the Disciplinary Code in the JPP to specific punishments for each offence, categorised in severity as referred to above. Each Rule has its own page or pages, where amongst various items listed is the “Sanctions available to the Tribunal”. There are two references on each page to the sanctions “available”.

As regards Rule 66, a signing ban was not listed as “available”. Mr O’Neill argued that, as a mere fine was insufficient, and in fact “ridiculously low”, and suspension, expulsion or termination too harsh, there must be a way to read into the Rule and available penalties something which amounted to a proportional and effective penalty. The argument as laid out by the AT was that the Tribunal could award anything which was less than the maximum penalty.

This did not find favour with Lord Glennie. He contrasted Rule 66 with Rule 62, where the maximum penalty listed was a fine of £1,000,000 and termination. However there was no provision for a suspension, expulsion or ejection from the Scottish Cup. He took the view that, if the SFA interpretation was correct, these lesser penalties could be imposed nonetheless. That, in his view, made no sense. Why specify different penalties for each offence, if the Tribunal could do whatever it liked up to the most serious penalty, even where the option chosen was not mentioned as a penalty for that offence? Accordingly the JP and AT were wrong to impose and upheld respectively the signing ban.

Why Did the SFA Argue the Case should have gone to the Court of Arbitration for Sport (CAS)?

Mr O’Neill referred to Article 5.1(c) which states that all members shall recognise and submit to the jurisdiction of the CAS as specified in the relevant provisions of the FIFA and UEFA statutes. The FIFA statutes put before the court require FIFA to provide the necessary institutional means to resolve disputes and to recognise CAS and allow appeals to CAS in certain circumstances.

The FIFA statutes do not require members to submit disputes to CAS and the Articles do not do so either.

In fact there are specific areas in the SFA Articles and Protocols where an appeal to the CAS is recognised, but these primarily relate to disputes between member clubs, or regarding player or agent registrations. The inclusion of specific rights of appeal to CAS in some cases implies that there no such general right. In particular, as the JPP lays down a process of having the case heard by the JP and with a right of appeal, although on limited grounds, to the AT, there is not necessarily a need for a further appeal.

In fact, as mentioned earlier, theses proceedings were not an appeal, but an application to rein in the SFA whose judicial arms had exceeded their jurisdictions. There are many cases in UK administrative law where, even if a body’s decision is stated to be final and not subject to appeal that can be reviewed if the “decision” is made in jurisdictional error i.e. ultra vires.

Mr Keen brought the court’s attention to two case, Ashley Cole v the FA Premier League, and Al-Wehda Club v Saudi Arabian Football Federation which Lord Glennie accepted were authority for the proposition that no appeal lay to CAS unless provided for in the national association’s rules.

CAS, as its name indicates, is a form of arbitration, and a hallmark of that is that parties require to agree to enter into it. In some cases contracts lay down that any disputes MUST be settled by arbitration. Here it is possible that Rangers could have asked the SFA if they could agree to take the case to CAS, but the SFA might well have refused on the basis that the JPP gave no right of appeal after the AT decision. In any event, Rangers did not ask to go to CAS, nor were they, in my opinion, obliged to do so.

Conclusion

This was a victory for Rangers, however it might well be a Pyrrhic one. My next blog will address where the issue might go from here, and the risks faced by Rangers and by Scottish football in taking this route.

Posted by Paul McConville

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34 Comments

Filed under Football, Football Governance, Rangers

34 responses to “Why Did Lord Glennie Find in Favour of Rangers in the Judicial Review against the SFA?

  1. Carntyne

    Chrystal clear as usual Paul.

    The corpse is beginning to stink.

    The funeral is long overdue.

  2. Leonard

    Paul,

    What Lord Glennie did was to give the AT a heavy hint as to what it might do next. He quoted the part of the AT judgement which said that it did not consider suspension on the basis that a signing embargo was competent. Such an embargo not being competent, guess what happens next. Pyrrhic victory indeed. Very poor advice. Very expensive too!

    • Carntyne

      Surely no lawyer would give advice that might end up lining his pockets through the good auspices of the Rangers Fighting Fund?

      They wouldn’t.

      Would they?

  3. KG

    An outsider looking in would have to say that the fitting penalty is suspension for 1 year.

    If they give a lesser penalty here, that being suspension from the Scottish Cup, what do the authorities do once a public admission is made that RFC did have dual contracts, this being a far more serious offence. This will surely result in suspension or demotion to a lower league.

    I would think it would be easier all round, for Rangers and the SFA / SPL, if Rangers were suspended now for 1 year for bringing the game in disrepute. Rangers can then form a Newco and come back the following season, making it easier for the authorities to deal with punishing the oldco for dual contracts (as it will be liquidated anyway) whilst they are out of the game for one year with the stripping of titles and cup wins.

    • Carntyne

      That won’t be easy.

      The leagues would be one team short, so presumably they would invite a non-league team to fill the gap, so there would be no room for a NewCo, Rangers or otherwise, after the one year suspension.

  4. Richboy

    Great analysis Paul which raised some very scary points for those from Govan. I would not call this a victory for Rangers. In my opinion, there five minutes left in the game, the score is one all and the ref has just awarded the other side a penalty. Whether they choose to score or not is another matter.

    It seemed to me that Lord Glennie was simply clearing the way for AT to suspend Rangers from the SFA/SPL.

    Imagine if roles were reversed for both Lords Carloway and Glennie. Glennie sits on the AT and decides that the embargo is not permitted therefore suspension is appropriate. Carloway then sits in the CoS and claims suspension is too harsh and suggests an embargo. Seems to me that it’s a toss of the coin as to how these judges mete out “justice”.

    • KG

      Richboy – your last paragraph makes a very good point.

      I suppose you can also look at this in terms of the SFA rules. If the rules did not prevent going to the Civil Courts then the SFA could appeal Lord Glennie’s decision and we then would be in the lap of the Gods as to what decision we’d get. But the SFA had to abide by FIFA’s rules and not continue the fight in the Civil Courts and take the decision back to the AT. The AT have already performed the role of judge and jury and are now getting the thumbs up from Lord Glennie, having dismissed the embargo penalty, that it is acceptable to go with the harshest of penalties available.

      The SFA’s rules, which Rangers were so arrogant in challenging, could now see the AT as a truly scary executioner (for Rangers).

      It is satisfying to see that the arrogance of Rangers and I include their administrators in this, is now finally coming back to haunt them.

  5. John

    Paul, great analysis. In your text, you mention two other cases that involved civil courts outwith football (Ashley Cole & Al-Wehda Club). What repercussions were the appropriate bodies forced to take by FIFA? Might it be the case that Rangers can again refer to these cases to show that there is no requirement for them to be punished for taking their Association to civil court?

    • Good question. Will check!

      • Cantona7

        John
        The citing of Ashley Cole and Al-Wehda was with respect to SFA stating that RFC(IA) sohuld have gone to CAS.
        Ashley Cole didn’t take his case to civil court. After appeal on original PL punishment, Cole attempted to take his case to CAS. CAS rejected it citing no jurasdiction on the dispute due to no ‘Right of appeal to CAS’ in PL rules.
        One presumes that Al Wehda’s case was also not seen in the civil courts, but appealed to CAS.

    • Ashley Cole did not go to the civil courts, he went to CAS who told him that they had no authority in the case because of an FA rule which said the governing body’s decisions are ‘final and binding’. Rangers argued that the SFA had an identical Rule.

      In 2005, Cole was fined £100,000 by the Premier League for meeting with Chelsea to discuss a transfer while he was still under contract to Arsenal. An appeal by Cole reduced the fine to £75,000 but he then took the case to CAS.

      The CAS ruling of August 31, 2005, stated that it had no jurisdiction over the dispute because the rules of the Premier League do not contain any reference to a right to appeal to CAS. Premier League rule R63 state that their decision is final and binding – exactly the same wording used in the SFA’s rule 65.3(b).

      FIFA have since said that Rangers would have had recourse to CAS.

      FIFA vice-president Jim Boyce has said that if a club or an association has complaints, or are not happy with whatever decision football bodies make, they have recourse to the CAS … FIFA and UEFA feel that is the channel people should go through.

      Cole was appealing the decision, he was not arguing that the FA was not competent to deal with the case in the way that they did. Rangers were, and they did not test it with CAS. This is why I would argue that Ashley Cole does not provide us with a precedent. It doesn’t. The situations were different.

    • Brian Jeffrey

      Not sure about this but my impression is that it is not Rangers who will be punished by FIFA & UEFA. They will seek to punish the SFA instead. FIFA satutes require the SFA to enforce the rule and they require the SFA to include appropriate rules in their own statutes to ensure that they can enforce the FIFA requirement. FIFA and UEFA will seek to punish the SFA for failing to enforce the FIFA statute. That punishment necessarily then involves the whole of Scottish football which is why the European campaigns for the Scottish clubs who qualified are all potentially in jeopardy meantime, as is the national teams participation in international tournaments.
      Therefore, in order to resolve that particular problem the SFA need to satisfy FIFA & UEFA that the SFA does indeed have amongst its own statutes the requisite means of enforcing the FIFA requirement and must then take steps against RFC to ensure compliance. FIFA in effect delegates the responsibility for the enforcement of the relevant FIFA statute to the national association and any failure by the national association to enforce the statute will render the national association liable to sanction by FIFA. If however the SFA do take action against Rangers to ensure compliance with the FIFA statute the threat against the SFA is lifted. To my mind however that necessarily means that the SFA sanctions must be sufficient to ENSURE that Rangers comply i.e the threat only goes away once Rangers are compliant (or suspended or expelled from membership).

  6. Enjoy the blog . It seems to me based upon this analysis that where Rangers could fall foul of FIFA re going to the civil courts is that they did not ask the SFA to agree to go the CAS. It may be that the SFA would have refused to agree but that is not the issue. Rangers did not exhaust every form of appeal/arbitration open to them before taking the case to the CAS. And that in my opinion may give FIFA and the SFA a rod to beat them with which might not have been available had Rangers gone to the Court of Session only after asking the SFA to agree to submit to the jurisdiction of the CAS.

  7. duggie73

    Why did Lord Glennie find in favour of Rangers in the judicial review against the SFA?
    Because as someone with a legal backgroung he is overwhelmingly likely to apply a set of rules strictly to the letter, regardless of whether or not those rules are badly drawn up.

    Frankly, the application could have been dismissed as frivolous since the breach of the rules did not result in a penalty which was disproportionate.

    Glennie’s advice to the appeals panel that a harsher sentence should be applied as the transfer ban is unavailable is useless in practice unless FIFA explicitly allow the SFA to have their ruling determined by a civil court.

    Dingy it and reapply the same penalty, it’s a stupid judgement.

    Nae lawyers on the pitch- them’s the rules.

    • Richboy

      “Dingy it and reapply the same penalty, it’s a stupid judgement”

      Very interesting point Duggie. Are the SFA (or any official body) allowed to ignore a decision from the Court of Sessions? If they did, what penalties, if any, could the Court of Sessions apply?

  8. sorry previous post should have referred to the Court of Session at the end of the fourth sentence (not CAS).

  9. Robert

    The Judicial Panel detailed verdict released by Gary Allan QC, the Tribunal Chairman, on 30 April, concluded that termination of membership of the SFA and suspension of membership were too severe taking account of Craig Whyte’s role in Rangers plight.

    The Appellate Tribunal statement released on 16 May stated “The sanctions available included expulsion from participation in the game and termination or suspension of membership of the Scottish FA, which would have had a similar effect. The Appellate Tribunal observes that serious consideration was given by the disciplinary tribunal to imposing one of these sanctions, which would have had obvious consequences for the survival of the club. The Disciplinary Tribunal rejected these as too severe and this Appellate Tribunal agrees with that conclusion”.

    In their petition to the Court of Session, Rangers sought a judicial review of the decision of the Judicial Panel, confirmed by the Appellate Tribunal, to prohibit registrations, on the basis that they did not have the power to use this particular sanction. Aidan O’Neill QC on behalf of the SFA argued, as recorded in the Opinion of Lord Glennie, “A fine would be ridiculously low for the conduct complained of. Suspension or expulsion, or termination of membership would be too harsh”

    As in all three occasions the SFA outcome, or argument, has been that suspension or termination of membership is too severe, it is difficult to see how it can now be successfully argued that suspension or termination of membership would now be appropriate.

    • duggie73

      … it is difficult to see how it can now be successfully argued that suspension or termination of membership would now be appropriate.
      ++++++++++++++++
      Well no, it’s easy.
      You refer the charges back from the appeal panel to the original one and add the disrepute brought to the game by RFC appealing through the civil courts (of course if you’re Glennie you think that an “appeal” is fundamentally different from an “application”, but for those not easily duped by synonyms…) then a harsher penalty is easily justified.

      • Richboy

        The JP thought that expulsion was harsh but also commented that the fine was not severe enough due to the severity of the “crimes” committed. They were obviously under the impression that they could apply other sanctions to balance this dilemna. I think it now comes down to which side of the harsh vs lenient argument they feel is most appropriate.

        I honestly don’t know where the SFA would stand legally if the punishment was increased, but I do not see Mr Green or D&P contesting another decision in the CoS.

    • Daniel Toye

      The JP and AT considered that suspension was too severe only in the context that an intermediate sanction (the embargo) was available to them. Now that is not the case, suspension is back on the table. Lord Glennie said as much.

      Could swing either way. But what is certain, Rangers are playing a dangerous game.

    • Carntyne

      The appeals panel now face a difficult choice.

      On the one hand its been decided a fine isn’t punishment enough, on the other termination of membership, expulsion of suspension is too severe.

      It may not matter very much anyway when the results of the two contracts investigation and the big tax case are delivered.

  10. thembeatles

    For a non-legal brain like mine I can only see 1 outcome here and that’s for the transfer ban to remain.

    How so? As Paul points out, the CoS has indicated that only 1 of the listed sanctions can be applied. So rangers have to accept the transfer ban, otherwise they will be suspended (as a minimum)

    Question is, will SFA have the mettle to tell them this and enforce it if necessary.

    I can’t see how they can protect the national team and the clubs due to compete in Europe from FIFA enforcing their position otherwise.

  11. Den

    Thr Judicial Panel verdict was damning and I said at the time would be much more damaging to Rangers than the punishment, I was not the only one to think it was on the light side.

    I felt that the part on actual sanctions was the weakest section of the report. Given that the offences were seen as second only to match fixing why were the top two sanctions too harsh? Why explicitly state that?
    My feeling was that the JP couldn’t countenance the consequences of those ultimate sanctions.

    They should just have defined the sanctions that they wanted to impose without commenting on harshness; the future appeals would have more discretion. My reading was that the JP were telling Rangers plainly that they were being let off lightly.

    Rangers had a case in arguing that the signing ban sanction was not available. To my thinkng only a complete eejit (or set of) would have appealed it; given the JP had made it clear that it was a let off. That they then apealed to the C of S makes me think that that they had better have a brilliant strategy in place.

    The decision could have gone either way and I feel that Lord Glennie could have dismissed the appeal and made Rangers think again, I feel that this would have been in the best interests of Football self Government while not precluding access to Courts in cases of clear injustice or prejudice. Rangers did not dispute the charges, or verdicts, or even the severity of the punishments. They were merely trying to wriggle out of punishment on a technicality. All in all though Lord Glennie’s decision was honest on the Law and facts a he saw it.

    I am sure that the AT are better equipped than I am to decide how to deal with the case but if they must choose from the limited menu it would seem that it is less of a stretch to go up than down. If they must mitigate the severity could they reduce the fine. On past performance it will not be paid anyway, if it is paid, £25k will cover the SFA Legal fees.

    Rangers will be lucky to be participating in Football next year never mind the SPL.

    It is not inconceivable that the AT will reduce the sanctions and Rangers will just have a fine that they will ignore but they have made powerful enemies. Possibly worse they will be seen as dangerous allies who will not hesitate to exploit perceived weakness (even in the form of mercy).

    Rangers have awoken FIFA. FIFA are a powerful and corrupt organisation: but after that there really is no comparison to Rangers.
    FIFA are global and in their World Rangers and SFA are minnows. FIFA will insist that the SFA slap Rangers down hard; even if the SFA ruin themselves while trying; because if they don’t they be finished off for not trying. FIFA have a gravy train to protect and it will not be derailed by some banana Republic on the edge of Europe who can’t control a morally, and more particularly, financialy bankrupt member.

  12. fisiani

    In two months season 2012-13 begins. What is the plan to cope with Rangers(IA) being initially suspended. 11 teams in SPL? Play-off game Dunfermline v Dundee? There are no rules to guide us. We only have 32 days till the fixture list is published.

  13. HighFibre

    I find it very surprising that no mention was made in the judgement of section 8.3.2 of the judicial panel protocol. This is the section which allows that “A Tribunal may, where it considers it to be appropriate to do so, in the interests of justice, depart from express procedural provisions within this Protocol. Where a Tribunal departs from express provisions of this Protocol, such shall not invalidate the proceedings.” I would have though the case rested on whether this only applied to matters not explicitly dealt with in the protocol, or in all judgements.

    • HF,

      8.3.2 is more, as I read it, to do with procedural “errors” rather than exceeding powers. There is an earlier clause that, at first sight, seems to give carte blanche, but, as Lord Glennie said, why specify the sanctions “available” for each and every offence, if the SFA Panel can pick anyone it wants, even one that does not exist as per the Rules!

  14. marty carmichael

    who cares if they can sign players what clubs are going to sell players to the strangers when they have nae paid for some they have and some they have sold on cannae see teams linining up to sell strangers anything

    • Don Paton

      Thanks Paul for shining your bright light upon the dark and mysterious thought processes that prevail among members of the High Court of Justiciary. I’m sure like most members of the laity the rational set out in the, normally, bald written decisions handed down are, often never fully understood. Might I suggest now that proposals, indeed pilots are underway to televise court proceedings, an opening be created for someone suitably qualified to summarise and explain both the machinations and excellent theatre that is the Law Courts system. I can’t rid myself of the thought that some day you might come to be regarded as the Bob Crampsey or John Motson of Court T.V. I can just see you now: “Welcome to tonights edition of Scotscourt.”

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