The 1928–29 Torquay United F.C. season was Torquay United's second season in the Football League and their second consecutive season in Third Division South. The season runs from 1 July 1928 to 30 June 1929.

Having finished bottom of the table for the 1927–28 season in only their first year in the Football League, Torquay United needed to apply for re-election in order to remain in the Third Division South. Fortunately, for the Magpies, the League members voted in their favour and manager Percy Mackrill set about rebuilding the team in an attempt to make a more competitive showing in their second League campaign. Mackrill made wholesale changes which meant an entirely new first eleven took to the field at Plainmoor on the first day of the season. Despite losing their opening game 4–3 to Queens Park Rangers, it wasn't long before Torquay began producing a much more attacking style of football, demonstrated by high scoring victories over Brighton & Hove Albion and Merthyr Town.

Perhaps the most impressive of all the new signings was the former Morton centre forward Bill Henderson who scored 10 goals in 15 games before his season was ended by injury in the home defeat to Coventry City in November. Also coming up with the goals were Cyril Hemingway and Bill Gardner, with Hemingway ending the season as top scorer with 12 in all competitions. Two other strong additions to the team were ex-England goalkeeper Harold Gough and full-back Jack Fowler who would become a crucial part of the Torquay defence for several seasons to come. Mackrill also managed to discover some local talent in the form of Babbacombe born Sid Cann. The promising young defender was only 16 when he made his League debut against Crystal Palace in September and made an impressive 17 appearances in his first season at United.

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