Refused Visitor VISA queries

Hi
I am trying to invite a friend from Morocco to visit the UK for 11 days holiday later this year, but have had the visitor visa refused based on 3 points: V4.2(a), (b) and (e).

Taking each in turn: (a) - UKVI concerned that the applicant will not return to their homeland. Evidence provided in respect of this was: marriage certificate / birth certificates of 3 children, letter confirming a full time employed position. Additionally, the applicant lives in a family owned house and this was advised. Also, return flights were booked in advance which demonstrated an intention to leave at the end of the holiday. (Flights were very cheap, so I was not concerned about losing this money).

(b) - UKVI do not believe that applicant is seeking entry to UK for a limited time - I have known the applicant for 9 years and my passport history shows a significant number of visits to Morocco since 2009. A quick flick through fb would show that I am friends with the applicant and their family as well as a number of the applicants friends.This is a tricky one to prove though, I guess...?

(e) - UKVI did not believe that applicant could meet the cost of the 11 day trip! (to be honest, I would agree) That is why I happily completed a full financial sponsorship undertaking, providing evidence of my home status, utility bills/correspondence from HMRC, evidence that I am an employed professional and will be taking leave for the proposed 11 day stay, payslips, bank statements showing amounts way in excess of what would be needed to financially cover an 11 day trip.

I thought we had put together a very strong application, so I was (& still am) confused as to why a refusal was issued.

Any input from anyone on this would be greatly appreciated. Thank you.

My proposed course of action is to submit a pre-action protocol (PAP) to the Home Office, and to do this without legal representation as the fee I have been quoted for that is somewhere around £720! As much as I want my friend to visit, that is a fee too far!

Does anyone have any experience of a PAP or any hints / tips on where to go from here?

Thank you for reading.