Passmore, Regina v: CACD 18 Jun 2007

P was claiming housing and council tax benefit. He had been convicted of dishonestly failing to give prompt notification of ‘a change of circumstances affecting any entitlement of his to any benefit or other payment or advantage under the relevant social security legislation’, contrary to section 111A. The court was asked the meaning of the phrase ‘a change of circumstances affecting any entitlement of his to . . benefit’.
Held: The change of circumstances must have made a difference to the amount of benefit which the recipient was entitled to claim in order for it to be characterised properly as a change of circumstances affecting his entitlement to benefit.
[2007] EWCA Crim 2053, [2008] 1 Cr App R 165
Social Security Administration Act 1992 111A
England and Wales
Cited by:
DistinguishedRegina v Lancaster CACD 2-Mar-2010
Whether Ommission Significant on Benefits Claim
The defendant appealed against his conviction for false accounting. He had been claiming council tax benefit and housing benefit, but had failed to notify the council of a change in his circumstances.
Held: The appeal failed. The court . .

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Updated: 21 April 2021; Ref: scu.259774