@halfcenturyup referred on the thread about the 115 charges to a discussion that he and I had some time back in which we agreed that significant parts of the PL rules are badly drafted. Some of those parts have no doubt been put together in haste to counter a perceived threat to certain vested interests that hadn't hitherto been appreciated by those with such interests.
However, looking at the text of the rules in their entirety, I take the view that the quality of much of the drafting simply isn't that good. Whoever the PL's in-house lawyers and external advisers were at the time the rules in question were drafted, they simply haven't done the job to the standard that I'd expect at this level of the profession.