of which at least 10 shall be flight instruction completed in a training course at an ATO. This training course shall include at least 4 hours of supervised solo flight time
If someone flew 10hrs of supervised solo time (including all the XC bits..but how?) he's technically met the requirements above (flown at least 4 hours S/S and met the 10 hours minimum)
Bad wording I guess.
Reading that again, I think the key lies in "training course at an ATO" like BillieBob says. Will talk to a school.