You could shoot a coach and horses through the ANO if you had a lawyer with the right attitude..... Starting with whether it was laid before Parliament properly.... And whether the CAA have permission in the Enabling Act to do certain things....
The CAA considers itself to be above such trivialities as the law. For example, I understand that the Senior Flight Examiner (for one) is continuing to conduct CPL skill tests despite not holding a Class 1 medical, in clear breach of the EU Regulation.