Judgment Approved by the court for handing down. [2025] EWHC 1170 (Admin) AC-2024-LON-001310 HUSAIN v SRA often sexualised language. Quite apart from any antisemitic content, some of the tweets were also overtly racist in other ways. 130. The Tribunal’s conclusion in relation to allegation 1.3 was also both properly open to it and clearly correct. The investigation of complaints against regulated professionals is an important public function. Staff working for regulators are entitled to work without being subjected to gratuitous abuse by those whom they are investigating. The comments made by Mr Husain to the investigating officer in this case were not only seriously offensive, but also made gratuitous reference to the officer’s race. There was no excuse for those comments. 131. The Tribunal’s conclusion, in relation to allegations 1.1, 1.2 and 1.3, that there had been a breach of principle (integrity), principle 2 (public trust) and principle 6 (encouraging equality, diversity and inclusion) was plainly open to it and, in my view, correct. Ground 4 Submissions for Mr Husain 132. Mr Magennis for Mr Husain cited the Tribunal’s Guidance Note on Sanctions, which provides at [48] that striking off will be appropriate only where the Tribunal has determined that “the seriousness of the misconduct is at the highest level, such that a lesser sanction is inappropriate” and “the protection of the public and/or the protection of the reputation of the profession requires it”. He described the tweets “in some instances offensive and foolish” but submitted that they evidenced a “relatively low” level of misconduct, which (i) involved no allegation of dishonesty, (ii) caused no loss or damage to anyone, (iii) involved no criminality and (iv) resulted in just two complaints to the SRA. Even if the SRA did not regard Dr Zaman’s report as reducing Mr Husain’s culpability to nil, it did reduce his culpability to a level below that required for striking off. The judgement does not explain why a lesser sanction would not suffice. 133. Mr Magennis relied on other disciplinary cases against solicitors, barristers and in one case a part-time judge, where lesser sanctions had been imposed for what he submitted was similar behaviour. Submissions for the SRA 134. Mr Solomon for the SRA submitted that this ground of appeal proceeds on a misconception as to the correct test on appeal. The correct test is as set out in Salsbury and James. Here, the findings in the Tribunal’s judgment on sanction were damning. Mr Husain repeatedly used racist and antisemitic language. His rudeness to his regulator was motivated by anger and outrage at being called to account. The distress he caused to people was entirely foreseeable and the level of harm was very high. His misconduct was deliberate and calculated and repeated, continuing as it did over a period of at least 9 months. It was motivated by the race and religion of the people about whom he was tweeting. There was an element of bullying. It was at times also puerile and crude. He had shown no insight and no contrition and the SDT was concerned he would behave in a similar vein again.