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Could be! The problem from photos is that the hairs on the eyes of torvus can be very indistinct, even under a microscope...you just cannot judge them in a photo at all, usually (even good photos like these).
My Flickr photos...
What didn't come out in the photos but was confirmed under the microscope is that the basal cells were extensively bare of microtrichia. I've added a photo which I think illustrates this.
Very thorough set of pictures! Looks good to me.
Lat/Lng: 52.061168, 1.159024
OS grid ref: TM166450