If ranking was a significant factor in the allocations, I can see a possible
argument for saying that qualification is not an issue, but still looking at academic evidence. (I can sense the 'opposition' asking "Will she fit in to an even more academically intense environment?
Your friend's case, of course, will be that bullying has affected performance. It might be a wise precaution to have some evidence of high achievement (prior to the bullying) available in case it's needed.
Is it worth pointing out that nearly all the classrooms have those horrid desks that seat 2 anyway so if a class can contain 31 (as at present) then it can just as easily contain 32. Also - so much work in KS3 and KS4 is in groups or pairs that 32 would seem easier to manage than 31. We also have reports from current pupils that most classrooms have 32 seats and some have 34.
Yes - a few gentle but probing questions!
"Could we ask if you normally have double desks or single?"
"Double? So a class could just as easily have 32 pupils as 31?
It really is difficult to know how to overcome the LEA's arguments.
If they know what they're doing, they really shouldn't lose their own case! Some appellants make the mistake of 'nitpicking' or being aggressive, neither of which goes down well with an appeal panel. If there are any serious weaknesses in the school's case, the panel should be more than capable of identifying them without assistance. It's fine to ask a few polite questions, but your friend should really focus on the case for the child. That's where the appeal is likely to be won or lost.