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It seems blindingly obvious that the SDT is at fault, finding someone guilty of something with which they had not been charged, aided and abetted by the SRA whose conduct on this matter was judged to be "intellectually virtually impossible to understand", a comment which could be applied to just abut everything the SRA does.
Such a decision can clearly not be allowed to stand.
One anticipates the same sanction will apply to Mr Malins at the end of the day, but at least he will have been dealt with fairly, which is not the current position.
The big fight will be over costs, but the SDT believes in unqualifed one way costs shifting, so expect Mr Malins to be paying for everything.