The Athlete, the Supplement, and the Sanction: Lessons from the Joshua Lynch Case
My protein shake this morning contained frozen raspberries, greek yogurt, soya milk and and a very well-known brand of whey protein powder (it was delicious). It did not contain as far as I am aware any substances banned by WADA. Rugby League player Joshua Lynch was not so fortunate. His case is a good illustration of the fact that in doping cases the key issue is often not just what’s taken, but how it got there.
The case of UK Anti-Doping v Joshua Lynch on 19 March 2025 reminds us that anti-doping rules are designed to uphold the integrity of sport while also recognising that athletes can and do make mistakes. Especially when it comes to supplement use. It’s also a case where the operation of Article 10.6.2 of the UK Anti-Doping Rules played a key role in reducing the period of ineligibility.
Joshua Lynch, a semi-professional with Rochdale Hornets, tested positive for ibutamoren. This is a growth hormone secretagogue (an agent that stimulates the secretion of hormones) prohibited at all times under the WADA Code. The positive result came from an out-of-competition urine sample collected in September 2023.
Importantly, UKAD accepted Mr Lynch’s evidence that he did not intend to cheat bringing Article 10.6.2 in to play. His evidence was that he had ingested a protein shake prepared by a friend which subsequently tested positive for contamination with ibutamoren. While the principle of strict liability still applied, this allowed for a potential reduction in the standard four-year ban.
What is Ibutamoren?
Ibutamoren is commonly marketed as a muscle growth and recovery aid. While it can increase levels of growth hormone and IGF-1, it’s not approved for medical use in many countries, including the UK, and carries a significant doping risk. It has been linked to contaminated supplements, often without being listed as an ingredient.
This highlights once again the perils of unregulated supplement use — and the importance of diligence, especially for athletes subject to anti-doping rules, no matter their level of competition. Bear in mind that this involved a semi-professional player being tested out of competition.
For a similar case involving Ibutamoren and a rugby league player see the decision in UKAD v Rob Worrincy.
The Role of ADR Article 10.6.2
The UK Anti-Doping Rules (mirroring the WADA Code) permit a reduction in sanction in cases of no significant fault or negligence, provided the athlete can demonstrate how the substance entered their system.
In Lynch’s case, the tribunal accepted that:
- He had declared the supplement.
- He had no intention to enhance performance.
- The contamination was inadvertent.
Under ADR Article 10.6.2, this justified a reduction to 16 months. The panel noted that this was “not a case of intentional cheating,” but also emphasised the need for athletes to be vigilant — a lower degree of fault is still fault, and the burden remains with the athlete.
Key Takeaways
For athletes, this case reinforces three crucial points:
- Supplements are high risk. Even if labelled as legal or safe, contamination is common. Batch-testing and certification are essential safeguards.
- Declaration helps. Transparency with anti-doping authorities counts, and declaring supplements can make a real difference in outcome.
- Strict liability still applies. Even unintentional ingestion can result in a lengthy ban.
For those of us working in the sports law and anti-doping space, Lynch’s case is another reminder of the balance the system tries to strike — between deterrence, education, and fairness.
You can read the full decision via Sport Resolutions here.