Judgment Approved by the court for handing down. [2025] EWHC 1170 (Admin) AC-2024-LON-001310 HUSAIN v SRA 53. The harm to those affected and to the reputation of the profession was high, and foreseeably so: [55]-[58]. The misconduct was deliberate and calculated and repeated, continuing over a period of 9 months: [59]. The misconduct was motivated by and/or demonstrated hostility, based on protected or personal characteristics of a person, namely race and religion. There was clearly a bullying element and puerile and crude sexual references: [60]. Other than a hitherto unblemished record, there was no mitigation. Mr Husain had shown “no insight whatsoever”: [62]. His apology to Mr Myerson was not genuine and he had shown “no contrition”: [63]. He had been unduly combative during the proceedings: [64]. He had transitioned from portraying himself as a “stout defender of freedom of speech” to being someone who was “angry and depressed and not able to control his impulses”: [65]. 54. In the circumstances, the Tribunal considered that the only sanction to protect the public and public confidence in the profession for this “ingrained behaviour” was an order that he be removed from the Roll: [66]-[70]. 55. The Tribunal considered Mr Husain’s means and made no order as to costs: [73]-[94]. Ground 1 Submissions for Mr Husain 56. Mr Magennis for the appellant submitted that the Tribunal irrationally concluded that the appellant was not disabled within the meaning of the Equality Act 2010 (“the 2010 Act”), wrongly excluded the psychiatric report and GP’s letter from its consideration of liability, contrary to the guidance in Bar Standards Board v Howd [2017] EWHC 210 (Admin), failed to make reasonable adjustments in breach of s. 20 of the 2010 Act (in that it refused to have the hearing on non-consecutive days) and failed to make findings in relation to breach of s. 15 of the 2010 Act. Submissions for the SRA 57. Mr Solomon for the SRA submitted that the Tribunal was correct to say that there was no evidence that Mr Husain was disabled. The psychiatric report of Dr Zaman was admitted only for the purpose of determining reasonable adjustments and mitigation. The decision not to admit it as relevant to the substance of the complaints was taken at a case management hearing separate from the final hearing and cannot be challenged on appeal. Howd turns on its facts and is not analogous to the present case. Section 15 of the 2010 Act is a definition section and is in any event not relevant. Discussion 58. In Howd, the Disciplinary Tribunal of the Council of the Inns of Court found six charges proven against a barrister. These related to his sexually inappropriate conduct on one evening at a party held by his former chambers. Lang J found at [21] that the medical evidence established on the balance of probabilities that “his inappropriate, and at times offensive, behaviour was a consequence of his medical condition”. At [48], she said: “if the public was aware that his behaviour was a consequence of a medical condition, and so lacked any reprehensible or morally culpable quality, it would be unlikely to diminish their trust and confidence in the profession or in Mr Howd as a