Yitty Friedman v (1) The Secretary of State for Work and Pensions (2) Moshe Friedman (UC): [2026] UKUT 362 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge West on 16 July 2026.
Read the full decision in .
Judicial Summary
Universal Credit – claimant commitment – ambit of grant of permission to appeal - Safi v Secretary of State for the Home Department [2018] UKUT 338 (IAC) at [38-47] - s.14(5) of the Welfare Reform Act 2012 requires that the claimant accept “the most up-to-date version” of her claimant commitments to count as meeting the s.4(1)(e) basic requirement - a claimant commitment can only be more “up-to-date” than an earlier commitment if in fact it has been updated - if there is no difference in the claimant commitment in a later document, a claimant will not fall foul of s.14(5) - given that there was no difference between the claimant commitment which the claimant accepted on 19 July 2024 and the one which she was asked to accept on 26 August 2024, the claimant commitment of 26 August 2024 could not lawfully be described as a more “up to date” claimant commitment: it was, on the contrary, not more up to date, but exactly the same.