Martin Paterson v Secretary of State for Work and Pensions (UC): [2026] UKUT 147 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge Citron on 13 April 2026.
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Judicial Summary
The Appellant had telephoned the Respondent’s Helpline in order to claim universal credit but been told (wrongly) that he had to wait three months in order to make a claim. Seven weeks later, he claimed universal credit, with the help of a Jobcentre, electronically. The Respondent, focusing on regulation 26 of the Universal Credit etc (Claims and Payments) Regulations 2013, decided that the Appellant’s award of universal credit ran from the date he claimed electronically, not from the date he phoned the Respondent’s Helpline. The First-tier Tribunal upheld that decision.
The Upper Tribunal finds that the First-tier Tribunal erred in law in not making the necessary factual findings to determine whether the Appellant had made a valid claim for universal credit by telephone (when he phoned the Respondent’s Helpline), applying regulations 8 and 10 of the above regulations. In the alternative, even if the First-tier Tribunal was right to find that the Appellant only made a valid claim for universal credit when he claimed electronically with the assistance of a Jobcentre, it erred in law in not making a factual finding as to when the Appellant first notified the Respondent that he needed such assistance. Both errors were material, as, on the facts of this case, the relevant factual findings could have resulted in the FTT concluding that the Appellant’s claim for universal credit was made on the (earlier) date on which he telephoned the Respondent’s Helpline.