Article 72 states that no licensing action is to be taken on a licence with no valid medical.
That is simply untrue - Article 72 states nothing of the sort.
Requirement for a medical certificate
72 (1) This article applies to any licence granted under article 64, other than a National
Private Pilot's Licence (Aeroplanes) or a Flight Radiotelephony Operator's Licence.
(2) The holder of a licence to which this article applies is not entitled to perform any of
the functions to which the licence relates unless the licence includes a valid medical
certificate issued under paragraph (4).
(3) Every applicant for or holder of a licence to which this article applies must, whenever
the CAA requires, submit himself or herself to a medical examination by a person
approved by the CAA, either generally or in a particular case or class of cases, who
must make a report to the CAA in such form as the CAA may require.
(4) On the basis of such medical examination, the CAA or the approved person may issue
a medical certificate which states that they have assessed the holder of the licence
as meeting the requirements specified by the CAA.
(5) Subject to articles 74(3) and 228, a medical certificate is valid for the period specified
in the certificate.
(6) A medical certificate forms part of the licence.
As has been pointed out here and elsewhere, the CAA's 'guidance' is increasingly flawed and at odds with the legislation and requirements.