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Presumably 11.59 their justification for seeking a change when they have a 90% success rate is that they believe everyone they investigate - but don''t chose to pursue to the SDT - is guilty of something.

So on the SRA/SDT's line of thinking there is a large demographic of people who are guilty of something but do not appear in the stats as they never get as far as the SDT.

Foreseeably they might in fact reduce their high success rate if the burden is lowered because then they will bring proceedings where they consider the chance of success is 51% rather than the 90%+ they presumably have now. This will result in a lot more people being accused of breaches who will successfully defend them.