Thank you – that’s a reasonable observation.
My understanding is that ARA.GEN.360 does not contain an explicit prohibition on transfer in cases where a medical has been revoked. The associated GM appears to envisage that full licensing and medical records, including any enforcement history, are to be transferred so that the receiving authority can make its own assessment.
I fully accept that SOLI is not designed as an appeal mechanism. However, if transfer were categorically refused in such situations, it would effectively mean that a single authority’s reinterpretation becomes structurally final, with no possibility of independent reassessment within the EASA framework.
That structural aspect is what makes the situation difficult.