Judgment Approved by the court for handing down. [2025] EWHC 1170 (Admin) AC-2024-LON-001310 HUSAIN v SRA Discussion 135. Given the limits of the appellate role in relation to sanction, when considering this ground of challenge, I have focussed on the Tribunal’s findings and reasoning on sanction, before considering whether these involved any error of principle or approach and then, if not, whether the ultimate decision was “wrong” in the sense that it was “clearly inappropriate” (Salsbury, [30]) or “falling outside the bounds of what the Tribunal could properly and reasonably decide” (James, [54], citing Bawa-Garba v General Medical Council [2018] EWCA Civ 1879, [2018] Med LR 561, [76]). 136. In my view, there was no error of law or principle or approach in the Tribunal’s consideration of sanction. Having heard from Mr Husain directly and at length, it was well-placed to judge the motivation behind the conduct complained of. As to allegations 1.1 and 1.2, it was entitled to conclude that this had shifted “from making potentially valid political points to being purely offensive and stooping to use racist and antisemitic language to underline his points of argument”: [49]. As to allegation 1.3, it was entitled to conclude that “his motivation appeared to be one of anger and outrage at being called to account by his regulator”: [50]. 137. The findings that Mr Husain’s behaviour resulted from a conscious decision and persisted over many months were open to the Tribunal and factually correct. The Tribunal clearly considered the medical evidence carefully but was entitled to conclude that there was nothing to explain why his depression would have caused him to be antisemitic and use racist and inappropriate, sexualised language: see [51]-[53]. 138. The Tribunal found that the harm to those who received Mr Husain’s tweets, and to the reputation of the profession, were both foreseeably high: [55]-[58]. These findings were open to the Tribunal. So were the findings that the misconduct was motivated by and/or demonstrated hostility, based on protected or personal characteristics of a person, namely race and religion and that there was clearly a bullying element and puerile and crude sexual references: [60]. 139. The Tribunal was also well-placed to judge Mr Husain’s attitude to his misconduct, some years after the tweets complained of. Its finding that he had shown “no insight whatsoever” was open to it, as were its findings that his apology to Mr Myerson was not genuine, that he had shown “no contrition” and that he had been unduly combative during the proceedings: [62]-[64]. 140. In the light of these findings, the Tribunal was entitled to be “concerned that the Respondent would behave in similar vein with clients and members of the public who did not share his views or who he perceived were challenging him”: [66]. This was a finding of particular importance when considering sanction. 141. In my judgment, the Tribunal explained adequately why it had concluded that no lesser sanction than striking off would suffice. In essence, it was because, having considered all the evidence and formed clear impressions about Mr Husain’s motivations at the time of the misconduct and his attitude at the time of the hearing, it was not satisfied that a lesser sanction would protect the public from a repetition of his behaviour. I