Judgment Approved by the court for handing down. [2025] EWHC 1170 (Admin) AC-2024-LON-001310 HUSAIN v SRA tweets “to determine whether they were, individually and/or collectively antisemitic and/or offensive or inappropriate, as set out in Allegations 1 and 2, and if it decided they were, then whether there had been breaches of the SRA Principles and professional conduct”. 84. These passages make clear that the Tribunal understood there to be two relevant questions in its analysis. The first was whether the tweets antisemitic and/or offensive or inappropriate. The second, which arose only if the answer at the first stage was “Yes”, was whether that amounted to a breach of the SRA principles and professional conduct. 85. The passages criticised by Mr Magennis at [27.31] and [27.34], [27.36.1], [27.37.7], [27.38.2], [27.38.11], [27.38.12] and [27.38.13] were all part of the first stage of the analysis. In these passages, the Tribunal used the terms “offensive or inappropriate” without using the qualifier “seriously”. However, it would be wrong to say that the Tribunal failed generally to consider how offensive the tweets were. At [27.38.11], it found that, in some of the tweets, “there was no nuance or subtlety and no attempt to obscure their meaning with such Tweets being plainly and deliberately crude and offensive”. At [27.38.12], it said that findings of antisemitism made the tweets “inherently offensive and/or inappropriate”, at [27.38.13] that some tweets directed at Mr Rifkind were “starkly offensive, absent any taint of antisemitism” and at [28.38.15] that the tweets set out in the table above had been “puerile, hurtful and gratuitously offensive” (emphases added). In my judgment, there is very little material difference between the language used here and an express finding that some of the tweets were “seriously offensive”. To all intents and purposes, it amounts to the same thing. 86. The findings at [27.38.17] and [27.38.25] in relation to breach of principles 5, 2 and 6 under allegations 1.1 and 1.2 (the second stage of the analysis) was therefore premised on findings which amount, in substance, to a conclusion that some of the tweets were seriously (rather than just barely) offensive. 87. The findings at [27.39.3] and [27.39.4] in relation to allegation 1.3 were that the tweets had “racist/discriminatory content” and were “intrinsically and overtly offensive”. Later, at [57], the Tribunal explained that the “distressing language regarding her ethnicity” used in communications to the SRA’s investigating officer amounted to “bullying and offensive abuse”. This too was, in substance, a finding that the communications in question were “seriously offensive”. 88. If there were any doubt about this, however, the Tribunal resolved it at [68]-[69], by saying in terms that Mr Husain’s conduct had been “both seriously offensive and seriously discreditable” in that there had been “many examples of antisemitic rhetoric, vulgar and offensive language, and racism”. 89. In my judgment, these passages show that the Tribunal did not misdirect itself as to the high bar required before concluding that Mr Husain had breached principles 2, 5 and 6 of the SRA Principles. Whether it gave proper effect in its decision to the principles underlying Article 10 is better considered under ground 3, to which I now turn.

Select target paragraph3