Regina v Westminster City Council and others ex parte M, P, A and X: CA 1997

Destitute asylum-seekers could derive benefit from section 21.
Held: ‘The destitute condition to which asylum-seekers can be reduced as a result of the 1996 Act coupled with the period of time which, despite the Secretary of State’s best efforts, elapses before their applications are disposed of means inevitably that they can fall within a class who local authorities can properly regard as being persons whose needs they have a responsibility to meet by the provision of accommodation under section 21(1)(a).’ The National Assistance Act 1998 was ‘a prime example of an Act which is ‘always speaking’ and so should be construed ‘on a construction, that continuously updates its wording to allow for changes since the Act was initially framed”


Woolf MR


[1997] 1 CCLR 85, (1997) 9 Admin LR 504


National Assistance Act 1948 21


England and Wales

Cited by:

CitedRegina (T) v the Secretary of State for the Home Department; similar CA 23-Sep-2003
The claimant asylum seeker had been refused benefits having failed to declare his application on entry. The Secretary now appealed a finding that the decision was flawed. Was the treatment of the applicant inhuman or degrading?
Held: No simple . .
CitedVictor Chandler International v Commissioners of Customs and Excise and another CA 8-Mar-2000
A teletext page can be a document for gaming licensing purposes. A bookmaker sought to advertise his services via a teletext page. His services were not licensed in this country, but the advertisements were. It was held that despite the . .
Lists of cited by and citing cases may be incomplete.

Immigration, Benefits

Updated: 12 May 2022; Ref: scu.186462