Club charged by FA.

[Quinn Upstone]

Thanks Spiv 🙂

[Blue_and_Gold]

For those that are interested, the full transcript that releates to the incident(s) that resulted in the £3,000 fine.

Last warning? Looks that way to me.   

Fairly condemning of the Club, but bright point was the positive feed back that our Safety Officer, Sarah Ryan, received. Well done.    It looks to me that without her prompt action, that the Fine (or other consequences) could have been far worse. Hopefully she received the thanks of the Club after they had received this report.

 

1
IN THE MATTER OF A FOOTBALL ASSOCIATION INDEPENDENT REGULATORY COMMISSION
BETWEEN:
THE FOOTBALL ASSOCIATION
and
KINGS LYNN TOWN F.C.
WRITTEN REASONS AND DECISION OF THE INDEPENDENT REGULATORY COMMISSION FOLLOWING THE HEARING ON 11 AUGUST 2025

2
INTRODUCTION & CHARGES
1. These are the written reasons for a decision made by an Independent Regulatory Commission ("the Commission") which sat by video conference on 11 August 2025.
2. The Commission members were Mr. Simon Parry, (Chairman, and Independent Legal Panel Member), Ms. Alison O'Dowd (Independent Football Panel Member) and Mr. Ken Brown (Independent Football Panel Member).

3. Mr. Michael O'Connor, FA Judicial Services Assistant Manager, acted as Secretary to the Commission.

4. The relevant incident took place in the National League North fixture between Kings Lynn Town F.C. ("KLTFC/the Club") and Scarborough Athletic F.C. on 7 December 2024.

5. By letter dated 23 April 2025 the FA charged KLTFC with two breaches of F.A. Rule E21.

6. Charge One alleged that in or around 65th minute they failed to ensure that its spectators and/or its supporters (and anyone purporting to be its supporters or followers) conduct themselves in an orderly fashion whilst attending the Match and do not use words or otherwise behave in a way which is improper and/or offensive and/or indecent and/or insulting with an express or implied reference to ethnic origin and/or colour and/or race, contrary to FA Rule E21.1 and E21.4.
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7. Charge Two is the same Charge relating to conduct in 75th minute.

8. By written reply dated 1 May 2025 the Club admitted the Charges and requested a paper hearing. The Club provided no material to the Commission by way of mitigation. The FA provided helpful Submissions on Sanction together with supporting documents.

9. The following is a summary of the principal submissions provided to the Commission. It does not purport to contain reference to all the points made, however the absence in these reasons of any particular point or submission should not imply that the Commission did not take such point or submission into account when the members determined the matter. For the avoidance of doubt, the Commission carefully considered all the evidence and materials provided to it.
FA RULE E21

10. FA Rule E21 states: A Club must ensure that spectators and/or its supporters (and anyone purporting to be its supporters or followers) attending any Match do not:
E21.1 behave in a way which is improper, offensive, violent, threatening, abusive, indecent,
insulting or provocative;
E21.2 throw missiles or other potentially harmful or dangerous objects at or on to the pitch;
E21.3 encroach on to the pitch or commit any form of pitch incursion;
E21.4 conduct themselves in a manner prohibited by paragraph E21.1 in circumstances where
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the conduct is discriminatory in that it includes a reference, whether express or implied, to one or more of ethnic origin, colour, race, nationality, religion or belief, gender, gender reassignment, sexual orientation or disability.
E21.5 It shall be a defence to a charge in relation to Rules E21.1 to E21.3 (only) if a Club can show that all events, incidents or occurrences complained of were the result of circumstances over which it had no control, or for reasons of crowd safety, and that its responsible officers or agents had used all due diligence to ensure that its said responsible was discharged. However, when considering whether this defence is made out a Regulatory Commission will have regard to all relevant factors including:
• The extent to which the Club has discharged its duty;
• The severity of the issues involved;
• The extent to which similar issues have occurred previously in which case whether the Club took sufficient action in preventing further such incidences.

FACTS
11. We turn first to the facts of the case. The principal evidence comes from the Match Referee, the Assistant Referee and video footage of the two incidents which was captured from within the terracing where the offensive behaviour was located. The incident in the 65th minute involved a spectator shouting "You ****ing queer". It is not readily apparent whether that comment was directed at a Scarborough player or at the Assistant Referee, although nothing turns on that point. However, the incident in 75th minute was very
clearly directed at the Assistant Referee. It involved a section of supporters from the same location as the first incident chanting "Lino takes it up the arse". Both the single outburst and the subsequent chanting are clearly examples of disgraceful homophobic abuse. On both occasions the Match Referee halted the game and followed the necessary protocol for incidents of discriminatory behaviour. After both incidents the Club made announcements over the stadium PA system. Only after the second incident were more stewards deployed to the relevant terracing.

12. Thereafter, the FA commenced an investigation and requested detailed observations from the Club. Sarah Ryan, Safety Officer for the Club provided full observations, together with the Matchday Stewarding Plan, the Matchday Briefing Sheet, the Ground Control Log for the fixture and an Incident Record Form from a member of security staff dated 7 December 2024.

PREVIOUS MISCONDUCT
13. Regrettably, this is not the first occasion that KLTFC has appeared before a Regulatory Commission for breach of Rule E21 in the context of discriminatory abuse. They were charged in respect of a home fixture in the National League North in September 2022. The abuse on that occasion was once again directed at an Assistant Referee. The case was ultimately considered by an Appeal Board who published Written Reasons dated 1 February 2023, which we have read and considered. In those Reasons it is recorded that the female Assistant Referee was subjected to persistent, offensive and misogynistic abuse. The Appeal Board, having allowed KLTFC's appeal imposed an Action Plan (a mandatory sanction for a first offence of its type) and a fine of £2,000. 14. The Action Plan was ordered to run until the end of the 2023/24 season. It was the subject of two audits by the FA in January 2024 and March 2024. We will return to the Action Plan and audits later. It is of great concern that the present breach occurred within months of that Action Plan ceasing.

FA SUBMISSIONS ON SANCTION
15. The Commission was assisted by very thorough written submissions on sanction. Those submissions remind us of each of the areas covered within the sanction guidelines section of The FA's Policy and Guidance on the Regulation of Discriminatory Conduct by Spectators. The guidelines are clear that "second or further offences will be treated with the utmost seriousness". We wholeheartedly agree with such a principle. They go on to observe that "there will be a presumption that the imposition of a further Action Plan shall not be appropriate (if the offence has occurred either during the period of the previously imposed Action Plan or within a year of the expiration of said Plan). We unanimously agree that it would be wholly inappropriate to impose a further Action Plan on KLTFC bearing in mind the proximity of the present breach to the expiration of the original Action Plan.

16. The Commission must consider the imposition of a fine within the published range for Clubs competing at National League North level, which is between £375-£5000. 17. Further, the Commission must consider the closure of a stand (or part thereof) of a Club's stadium for a specified number of Matches - a "Partial Stadium Closure" and the closure of a Club's stadium for a specified number of Matches - a "Full Stadium Closure".
11. We now turn to each of the factors relevant to the type and level of sanction that we are required to impose. The first factor which we have regard to is the number of spectators involved. We note that Charge One involves a single spectator. However, his behaviour was no doubt a catalyst for a greater number of spectators to engage in similar misconduct in the second incident. Whilst it cannot be determined with any certainty how many people were involved in the second incident, it was clearly more than a handful. We also note that the misconduct took place in front of children present in that terracing which, in our judgment, is a highly aggravating feature.
The second factor is the nature of the behaviour. The comments used by the spectator(s) were plainly homophobic in nature. It was deeply offensive to the Match Official.
The third feature is the duration of the incident. Both incidents, as can be seen from the video footage were, fortunately, brief.
The fourth factor is whether the Club and/or its officers took all reasonable steps in its preparation and planning for the fixture in which the relevant breach occurred; whether the Club and/or its officers took all reasonable steps in dealing effectively with the incident when it arose and whether the Club and/or its officers took reasonable steps in identifying the supporters involved. We can see from the Matchday Briefing Sheet that racism, homophobia and misogyny were all identified as behaviours to be challenged and, if heard, more staff to be deployed to the area. Having watched the footage, it seems to us that there was an insufficient response to these incidents both in terms of challenge and also in the numbers of staff deployed to the area concerned. We further note from the Club's observations that not one single person has been identified and dealt with, either on the day or subsequently. In our judgment that is a woeful reflection on the deployed security staff and the Club.The fifth factor is co-operation with the FA. We accept that the Club co-operated with the FA's investigation and Sarah Ryan is to be commended for her full response to the FA. The Commission accepts that she is trying to discharge her duties as Safety Officer in a professional and effective way. However, the repetition of this sort of unacceptable behaviour is a Club issue that has to be addressed not by the Safety Officer alone. It is disappointing to see that the Club has not submitted any evidence or submissions by way of mitigation.
The sixth factor is the Club's previous record. We have already addressed this above. The fact that the Club is now facing its second discriminatory crowd control incident so soon after the expiration of the Action Plan has to be considered as a substantial aggravating factor.

17. The final factor to consider is the Club's compliance with the Action Plan. The FA addressed this factor in their submissions. We have had the benefit of reading both audit reports. The FA note, in particular, the six recommendations from the second audit in March 2024, which we reproduce here, given their importance.
Recommendations.
1. Use the pre-match management meeting as an opportunity to sign off the risk assessment for every match. Even if this looks like the generic risk assessment for most games, the process will show that a degree of auditable scrutiny has been applied to the threat and risks associated with each individual fixture
2. Continue the work aimed at producing a condensed version of the Stewards' Handbook that staff can readily access. This product should contain the key messages that the Safety Officer wishes staff to have immediately at hand. The Safety Officer has a vision of what she wants, and some of the tools that she needs to make this vision a reality. This should be in place for the start of the new season at the latest
3. Produce a script for the PA announcer to read out ahead of the match in a preventative move to discourage discriminatory chanting and state that it will not be tolerated. KLTFC have a reactive message ready to be read out once the behaviour has occurred, but the club should develop a separate message to be read out that should warn against:
a. Misogynistic chanting and behaviour
b. Racist and homophobic abuse
c. Offensive comments and behaviour
d. Any other behaviour they wish to discourage (e.g., the throwing of missiles; use of pyrotechnics; staying off the field of play)
Produce a new video message with members of the 2024/25 first team squad to be played ahead of each home game which emphasises the club's zero tolerance approach to discriminatory behaviour, and its desire to be an inclusive club for all
Continue staff and supporter education programmes so that conversations around equality,
diversity and inclusivity issues become normalised. This would include working with Kick It
Out and significantly upgrading signage around the stadium
By the start of the 2024/25 season produce and publish a King's Lynn Town Supporters'
Charter. This document:
a. Should have an emphasis on what it means to behave like a KLTFC supporter
b. Should be published on the club website and accessed through a clearly labelled link or button referring to it being the Supporters' Charter
c. Should be referred to on a regular basis in communications with fans, in social media feeds
and used as a discussion point in Supporters' Forums.
18. These recommendations go to the heart of trying to prevent discriminatory abuse from spectators towards players, officials and opponents. Their importance cannot be understated, and we would expect to have seen the Club enthusiastically embracing those recommendations. As it is, there is no evidence before us that any of those recommendations have been adopted. None of the recommendations involve a substantial financial outlay and thus the failure to adopt can only be seen as a Club unwillingness to accept the constructive advice offered. As the FA notes in its submission, there is no reference in the Club's observations to the March recommendations. Therefore, we are driven to the conclusion that the original Action Plan has not been adopted as fully as it should have been which must be treated as an aggravating factor.

CONCLUSION
18. Bearing in mind that this is a repeat offence of discriminatory abuse the Commission is firmly of the view that any further Action Plan would have little, if any, effect on the Club. As we have identified, the fact that this occurred within the earshot of children further aggravates the Club's position as does the Club's failure to evidence any meaningful response to the original Action Plan and most recent audit of the Action Plan. We have no hesitation in determining that this is an extremely serious case. The aim of our sanction has to both punitive and deterrence. There is, in our view, an increasing prevalence for this type of behaviour in society in general and in football.
19. We conclude that in all the circumstances of this case, the time has come for a severe sanction to reinforce the message to KLTFC and others that discriminatory abuse has no place in football and that clubs will be punished when they repeatedly fail to fulfil their responsibilities. In our judgment, this is a case that calls for a closure order. We do not conclude that it would be appropriate for that to be a Full Stadium Closure, taking account of the Club's admission of the Charge and the fact that this is their second offence rather than third or fourth. However, the Club should be under no illusion that unless positive change is affected, then they run the very real risk of a future Commission imposing such an order.

20. Therefore, bearing in mind the seriousness of this case we impose a Partial Closure Order for the next two home fixtures to be played by KLTFC following the issuing of these Written Reasons. We have determined that the Partial Closure shall be in respect of the North Terrace, save for that section designated for away fans, as we see no reason to penalise them. We are conscious of the fact that the Closure Order will likely disperse those problem supporters responsible for this incident to another area(s) of the stadium, however, that should make the policing of them more effective.

21. There will also be a financial penalty commensurate with the seriousness of the case. In our judgment an appropriate starting point is one of £4,500. We reduce that to £3,000 to take account of the Club's admission of the Charges and the fact that we have imposed a Partial Closure Order.

22. Furthermore, we exercise our powers under FA Disciplinary Regulation 41.9 to order that KLTFC, upon publication of the Regulatory Commission's Written Reasons, shall communicate via the Club website, via social media and in the matchday programme for its next home match an appropriate message and response to their supporters. Such message and response should explain the background to the Charges, the Club's condemnation of the homophobic behaviour that underpinned the Charges, the sanction imposed on the Club by the Regulatory Commission and the initiatives the
Club is to develop, to make the Club more inclusive and more proactive in the prevention and detection of any potential discriminatory or inappropriate words or behaviour going forward. The Club shall thereafter introduce an appropriate media campaign across the Club website and the Club's social media accounts emphasising the Club's policies and zero tolerance toward discriminatory abuse.

SANCTION
23. Kings Lynn Town FC shall be subject to a Partial Closure Order for two (2) consecutive First Team Competitive home matches at The Walks Stadium, limited to the North Terrace, save for that section designated for the use of away supporters. Such Partial Closure Order shall take effect 14 days from the date of the publication of the Written Reasons.

24. Kings Lynn Town FC shall be fined the sum of £3,000.

25. Upon publication of the Regulatory Commission's Written Reasons, shall communicate via the Club website, via social media and in the matchday programme for its next home match an appropriate message and response to their supporters. Such message and response should explain the background to the Charges, the Club's condemnation of the homophobic behaviour that underpinned the Charges, the sanction imposed on the Club by the Regulatory Commission and the initiatives the Club is to develop, to make the Club more inclusive and more proactive in the prevention and detection of any potential discriminatory or inappropriate words or behaviour going forward. The Club shall thereafter introduce an appropriate media campaign across the Club website and the Club's social media accounts emphasising the Club's policies and zero tolerance toward discriminatory abuse. 26. The decision is subject to any appeal as provided by the Regulations.


Mr. Simon Parry (Chairman)
Ms. Alison O'Dowd
Mr. Ken Brown
19 August 2025

[Linnet465]

  I am afraid until the problem supporters are rooted out and banned as an example abuse will continue.
The move of changing the away and home teams touch line hut has quietened some abuse given by a few in the hospital end of the paddock. That was a good easy idea.

[Mallard]

Must be a nightmare to police with fans always having a pop at Lino's.

I guess with video footage of the culprit (s) at least they can make sure those people are kept out of the ground.  Has Bal issued any banning orders or last last chance salon's to anyone?  That part seems straight forward to manage.

How they stop one individual from shouting abuse I have no idea.  I guess with a strong security and steward presence it may prove a deterrent. 

[Blue_and_Gold]

Must be a nightmare to police with fans always having a pop at Lino's.

I guess with video footage of the culprit (s) at least they can make sure those people are kept out of the ground.  Has Bal issued any banning orders or last last chance salon's to anyone?  That part seems straight forward to manage.

How they stop one individual from shouting abuse I have no idea.  I guess with a strong security and steward presence it may prove a deterrent. 

It will be interesting to see the outcome of this and what Bal decides.

A suggestion. Some of the people that now like to hang out in the Officials Lounge, may want to mix with the supporters a bit more. In particular the areas that tend to be the hotspot for trouble.

I remember that being done when Chapman's were here, and even prior to that with the old Club during the Bobbins era.