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Tetrahedral complexes - LFSE Question?

why is it that d5 octahedral complexes may exist in either high spin or low spin configurations, but d5 tetrahedral complexes are always in a high spin configuration?

I know that almost all tetrahedral complexes are high spin because delta t is much smaller than delta o.

how can I explain the above question using the CFSE splitting diagram?

thank you

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