[2008] EWCA Crim 1745

Where an offender had made false representations and had therefore never been legitimately entitled to claim social security benefits, the offence of failure to declare a change of circumstances contrary to the Social Security Administration Act 1992 s.111A(1A) had not been committed, as an essential element of the offence, namely a change of circumstances, had not occurred.

CA (Crim Div) (Latham LJ (VP CA Crim), Grigson J, Judge Pert QC)

16/07/2008