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Another curious aspect is that the SRA's solicitors had acted for the NHS in some of the underlying cases:

"Concerns had been expressed to Capsticks as regards
its representing the NHS LA, the complainant in this matter, and the SRA who, as the regulator, brought this matter.
Whilst it did not accept that a conflict existed, Capsticks, in correspondence dated 13 November 2017 confirmed that the SRA would not to [sic] rely upon any matters where it had previously acted" (judgment, paragraph 7.1).

This is the sort of problem which the SRA creates for itself by only using one firm of solicitors for SDT cases. Here, the upshot was that the SRA gave up the right to rely upon anything where Capsticks had previously acted.