Gerry Strain, the former director of football at Hamilton Academical, has obtained permission from the Court of Session to proceed with a Judicial Review of the Scottish Football Association's decision to label him 'not fit and proper' in November 2025. The ruling, issued by Lord Lake QC on June 19, 2026, allows Strain's petition to challenge the SFA's determination on five specific grounds.
Background of the SFA Ruling
In November 2025, the SFA deemed both Strain and then-Accies owner Seref Zengin 'not fit and proper,' imposing bans from involvement in football club management. While Zengin accepted the judgment, Strain has contested it ever since. The SFA's decision was based on Article 10 of its rules, the 'fit and proper person' test, which assesses an individual's suitability to own, direct, or exert significant influence within Scottish football.
Lord Lake ruled that the statutory test for permission had been met, setting a procedural hearing for July 30, 2026, and a substantive hearing for September 29, 2026. The five grounds for review include procedural fairness, the correct application of Article 10, whether relevant material was properly considered, whether adequate reasons were provided, and whether the sanctions imposed were proportionate.
Strain's Argument and Court's Refusal
Strain also argued that the SFA failed to account for the club's position and prior sanctions when imposing a 15-point penalty on Hamilton Accies, which contributed to their relegation from the Championship in the 2024/25 season. However, the court refused this ground, stating that it primarily concerns the club's position, not Strain personally.
The Judicial Review will now examine whether the SFA acted lawfully in its decision and sanction against Strain. In a statement to Lanarkshire Live Sport, Strain said: “I have maintained from the beginning that I was entitled to a fair process and a lawful decision. The Court has now determined that my challenge raises substantive issues that require a full hearing, and I look forward to presenting my case before the Court of Session. This case is not about challenging the Scottish FA’s ability to regulate the game. It is about ensuring that such regulatory decisions are reached fairly, transparently and in accordance with the law.”
SFA Response and Next Steps
The Scottish FA was contacted for comment on June 23 and again on June 29, 2026, but did not provide a response. The upcoming hearings will determine the outcome of Strain's challenge, with implications for how the SFA applies its regulatory powers.
