I think the Umbridge version is uncontroversial: someone who uses existing rules or creates new rules (like the lifeguard in the Scott’s description, or the agencies making it intentionally hard to get reimbursed) to disguise their real intentions, that have nothing to do with following the rules and everything with achieving nefarious goals, be it torturing HP, getting rid of a kid they don’t like, or maybe getting a bonus for minimizing expenses.
I think the Umbridge version is uncontroversial: someone who uses existing rules or creates new rules (like the lifeguard in the Scott’s description, or the agencies making it intentionally hard to get reimbursed) to disguise their real intentions, that have nothing to do with following the rules and everything with achieving nefarious goals, be it torturing HP, getting rid of a kid they don’t like, or maybe getting a bonus for minimizing expenses.
Also, someone wouldn’t have to be fully as bad as Umbridge to qualify as “sufficiently Umbridge-like”.