“Eligibility for and provision of accommodation to a failed asylum-seeker ‘(1) Subject to regulations 4 and 6, the criteria to be used in determining the matters referred to in paragraphs (a) and (b) of section 4(5) of the 1999 Act in respect of a person falling within section 4(2) or (3) of that Act are- (a) that he appears to the Secretary of State to be destitute, and (b) that one or more of the conditions set out in paragraph (2) are satisfied in relation to him. (2) Those conditions are that— (a) not relevant to this appeal…. (b) he is unable to leave the United Kingdom by reason of a physical impediment to travel or for some other medical reason; (c) not relevant to this appeal…. (d) not relevant to this appeal…. (e) the provision of accommodation is necessary for the purpose of avoiding a breach of a person’s Convention rights, within the meaning of theHuman Rights Act 1998 .”
‘(1) …(not relevant); (2a) if the Secretary of State decides not to provide accommodation for a person under section 4, or not to continue to provide accommodation for a person under section 4, the person may appeal to the First-Tier Tribunal. (3) On an appeal under this section, the First-Tier Tribunal may – (a) require the Secretary of State to reconsider the matter; (b) substitute its decision for the decision appealed against; or (c) dismiss the appeal.’
“where a person whose application or claim for leave to remain is being considered requests the return of his passport for the purpose of travel outside the common travel area, the application for leave shall, provided it has not already been determined, be treated as withdrawn as soon as the passport is returned in response to this request.”
“Under regulation 3(2)(e) of the 2005 Regulations Caseworkers must consider whether support under Section 4 is necessary in order to avoid a breach of a person’s ECHR rights. It is for the applicant to provide evidence that a refusal to provide support would be a breach of their ECHR rights... Applicants are most likely to establish that they should be supported under regulation 3(2)(e) if they cannot be expected to take steps to leave the UK and so avoid the consequences of destitution that might lead to them suffering inhuman and degrading treatment. The most common case types where this applies (the list is not exhaustive) are when: - The applicant has submitted a late appeal against the Secretary of State’s decision to refuse asylum and the AIT is considering whether to allow the appeal to proceed out of time. - The applicant has submitted further submissions which are outstanding. These are examples only …”
“….. Some applicants may submit an application for Section 4 support on the basis that they have made further submissions, which are still outstanding. The existence of the submissions, combined with the fact that the person does not have access to accommodation and the means to live (or will shortly be in this position) may mean that support needs to be provided in order to prevent a breach of their human rights. The relevance of the further submissions in these cases is that they constitute the factor that may demonstrate that the applicant cannot be expected to take reasonable steps to leave the United Kingdom - and so avoid the consequences of being left destitute in circumstances that would otherwise lead to a breach of their human rights. It is therefore important that caseworkers makes every effort to consider the further submissions at the same time as consideration is given to the Section 4 application; in order to check that the further submissions are not clearly abusive, manifestly unfounded or repetitious. Where it is clear that these factors apply the Section 4 application should be refused, which in practice will be at the same time as the further submissions are rejected. …”
“… there is no material before us to suggest that the Secretary of State routinely exercises his discretion to determine an application for leave to remain notwithstanding that the applicant has left the UK. Accordingly, local authorities should approach their task on the footing that if, by withholding assistance, they require a person to return to his country of origin, that person’s application for leave to remain will be treated by the Secretary of State as withdrawn.”
“ ….that when applying Schedule 3, a local authority should not consider the merits of an outstanding application for leave to remain. It is required to be satisfied that the application is not “obviously hopeless or abusive”…. Such an application would, for example, be one which is not an application for leave to remain at all, or which is merely a repetition of an application which has already been rejected. But obviously hopeless or abusive cases apart, in my judgment a local authority which is faced with an application for assistance pending the determination of an arguable application for leave to remain on Convention grounds, should not refuse assistance if that would have the effect of requiring the person to leave the UK thereby forfeiting his claim.”