“It was put to the Tribunal that the late Mr A may have had his own reasons for inventing a wife when he was working in the UK in the 1960s, and further good reason for killing off the said “wife” by the mid 70s, namely that fraudulent claims of Child Tax Allowance were common in immigrant communities during the 1960s, and these allowances were abolished from 1975. At the Tribunal hearing evidence was presented that Mr A’s tax code reduced substantially in the 1974/5 tax year.” 31. Mrs A’s representative makes the further remarkable claim in her written submissions that “I have seen numerous benefit cases where pre-1975 dependants were invented for tax purposes, and many of these people could not remember and give consistent details of those that they invented. I have also been told by many men that in the late 1970s they had to repay the Revenue because of this type of fraud, particularly where they were then seeking to bring their genuine wives to the UK.” 32. Rather than peremptorily dismissing this argument (which I consider further in the Appendix to this decision), the FTT should have weighed this explanation in the balance. It could not simply disregard it without further ado because Mr A had apparently acknowledged a prior marriage in his 1975 statutory declaration. In my view, Mr A’s evidence in the round should have been treated with some circumspection. True, he had, by inference, accepted in the statutory declaration that there had been a valid marriage in 1948/49. However, in one of his answers to the DSS enquiry form in respect of his 2003 retirement pension claim, he denied ever having been married to anyone else, signing a declaration to the effect that the information given was correct and complete and that if not “action may be taken against me”
“… So, the burden was on the adjudication officer (now the Secretary of State). There was some evidence of another marriage, but it was very weak. The question I ask myself is this. If the evidence of the other marriage that is before me was used as the basis for a claim for a retirement pension, what would the decision be? The answer can only be that it would be rejected as insufficient to prove the existence of a marriage. On that basis, the Secretary of State has not proved that there was another marriage.” 35. This evidence must now be weighed in the scales against the evidence to the contrary. The evidence that there had not been a marriage between Mr A and Mrs J in 1948/49 36. The contemporary evidence of any such marriage in 1948 or 1949 is non-existent. There is no evidence of the precise date of the alleged marriage. There is no marriage certificate or any other contemporary documentation. There is no evidence from any third parties about the supposed marriage. However, none of this is fatal to the case for there having been a marriage. This is for the simple reason that the event in question, assuming it took place, happened a long time ago in a society with different customs and practices. As Mr Commissioner (now Judge) Jacobs observed in CP/4062/2004, commenting on the availability (or otherwise) of contemporaneous documentary evidence of births or marriages: “13. This is an inevitable feature of cases involving countries in which there is no reliable system of registration of important life events like birth, marriage and death. It is a neutral factor in the assessment of the evidence. It hampers the genuine claimant in making her case, while providing an opportunity for deceit by the dishonest claimant. The decision-maker and the tribunal have to decide whether the claimant is genuine or dishonest. It is wrong to approach that task by taking the lack of contemporaneous evidence as a factor that is against the claimant. To do so would be to assume what has to be decided.” 37. A further consideration is that Mr A was obviously a child at the time of the alleged marriage in 1948 or 1949. It is said that Mrs J was too. Again, this does not, of itself, mean that a valid marriage did not take place.The Child Marriage Restraint Act 1929 , originally enacted in British India, applied also to Pakistan. It provided for minimum ages for the marriage of boys (18) and girls (14, later raised to 16 by the Muslim Family Law Ordinance 1961), backed up by criminal sanctions. Such marriages were voidable by the child bride on attaining majority. As the standard legal textbook on the subject notes, “While very early marriages are widely perceived as socially undesirable, and the average marriage ages in South Asia are in fact slowly going up, most child marriages never come to the notice of the authorities, hardly anyone gets penalised, and such marriages have consistently been recognised as legally valid” (D. Pearl and W. Menski, Muslim Family Law (3 rd edition, 1998) at p.155, [6-55]). 38. So the absence of contemporary evidence and the fact that the parties were children at the time of the alleged marriage is not decisive either way. There are, however, a number of factors which do suggest that no such marriage took place. In no particular order, they are as follows. 39. First, the FTT had before it Mr A’s old-fashioned national insurance (NI) account card (or “RF1”). This recorded his name, address, marital status, occupation NI contributions and credits etc up till the first basic computerised system in 1975. Mr A’s RF1 was opened in 1962, shortly after his entry to the UK. The entries for marital status or spouse were all left blank. This is the oldest document on file. It shows that Mr A made no declaration to the Department between 1962 and 1975 (the final entry being5 October 1975 ) that he was or had been married, let alone married to Mrs J. 40. Second, the FTT also had before it a copy of the original certificate of marriage between Mr and Mrs A in 1975 and an authorised translation into English. In the English version, Mrs A was described as a “spinster”; however, the answer to the question “Does the bridegroom have another wife? If so, did he obtain permission of the Arbitration Council under Muslim Family Law Ordinance 1961?” was left blank. In the original Urdu text, however, diagonal or crossed lines had been entered, presumably indicating that no relevant information needed to be included. 41. Third, Mrs A and her son gave clear and consistent evidence to the FTT that Mr A had made no mention whilst he was alive of Mrs J or the alleged four illegitimate children that she had had. They had also made extensive enquiries of family members, none of whom could confirm the existence of Mrs J. An obvious riposte to this is that little weight should be attached to this particular evidence, as it was self-serving. However, Mrs A also gave evidence that her marriage to Mr A was an arranged marriage, that he was then aged 37 and she was 19, and that she had discussed the matter with her late father, who had said that he would have been aware of any previous wife. 42. Fourth, and finally, the validity of Mrs A’s marriage had twice previously been investigated by the UK authorities. In the first place, the Home Office had approved Mr A’s application for entry clearance for Mrs A in 1976 before she entered the UK. None of the relevant documents were before the FTT. However, it is not unreasonable to assume that that application was approved only after the usual types of enquiries were made. 43. Subsequently the Department’s specialist Validity of Marriage Unit (VMU) had conducted its own investigation into Mr A’s marital status in the course of 2003 and 2004 before the decision was taken to award the ADI for Mrs A as part of his retirement pension. That investigation included an interview, the transcript for which is no longer available as the Department has destroyed all the relevant papers under its normal protocols for retaining or disposing of historic documents. It doubtless included other relevant material, including both other evidence and opinions from VMU staff on that evidence. The Department was well aware at that time of the possibility of a previous marriage with Mrs J, yet the advice was given that the marriage to Mrs A was valid. 44. In its submission to the FTT, the Department sought to deal with this matter in the manner explained in paragraph 10 above, by reference to reported Social Security Commissioner’s decision R(IS) 11/92. However, as Mr McClure submits, “if the intention of the reference to R(IS) 11/92 was effectively to rule the Secretary of State’s favourable ADI decision out of evidence before the tribunal, then that intention was ill-founded. The Secretary of State makes correct decisions in the vast majority of cases, and the ADI decision would not have been made without reference to the relevant evidence, and a determination that on the balance of probabilities that the claimant was validly married to Mr A.”
“The Appellant’s appeal is allowed. The Appellant is entitled to bereavement benefit. The marriage between her and Mr A on11 October 1975 was a valid marriage. Mr A had not previously been married to Mrs J in 1948 or 1949. The Secretary of State’s decision issued on1 March 2011 , and revised on13 September 2011 , is further revised accordingly.”