Tr;
Your argument is erratic and frankly bizarre Sid.
You clearly don't understand what 'qualified' means in this sense. Are you a line blurrer? A fudger? The answer is obvious!
Ask the CAA if they consider any of the individuals you mention to have the necessary experience (never mind QUALIFICATIONS!!) to be a licensed crew member on a police EC135!
In case you didn't know. Cabin crew don't have 'licences' either. Just like your TFOs!
As far as your licensing authority is concerned, it's all down to you. Stop trying to pretend otherwise.
Hold on, you said "
But they have absolutely no aviation qualification whatsoever."
Disregarding the individual licences aviation qualifications that I mentioned earlier, I think you'll find that police observers are indeed 'qualified'. If you don't think this is the case, please tell us your definition.
Here's something from the CAA that you may be interested in, that's online and I can refer you to;
http://www.caa.co.uk/docs/33/CAP612.PDF
If you think that Police Observers/TFO's are really just passengers, I strongly suggest that you read part D.
Seems a lot of CAA boxes to tick if they are just a pax!