Www.emlawshare.co.uk Prevention of Social Housing Fraud Act 2013 Simon Kiely Solicitor, Sharpe Pritchard LLP

www.emlawshare.co.uk

Prevention of Social Housing Fraud Act 2013

Simon Kiely

Solicitor, Sharpe Pritchard LLP


The scale of the problemIn October 2013, it was estimated that there was around 98,000 unlawfully occupied social homes in England. This figure was based on an assumption that 4% of all housing stock in London was being unlawfully occupied.

Prior to this Act coming into force, there were two main problems faced by Local Authorities in dealing with social housing fraud:

1. Inadequate deterrents – Fraud Act offences not fit for purpose and threat of being evicted from a property which the fraudster might not be living at is pretty thin!

2. Inadequate powers to investigate offences

Although this Act started life as a Private Members’ Bill by Richard Harrington MP (Hon. Member for Watford), it received cross bench support.


Existing criminal sanctionsThere were a number of relatively minor successful prosecutions achieved by a number of London Boroughs to prosecute unlawful subletters under the Fraud Act 2006. The reason for the small number of offences was due to large number of elements that are required to successfully prove a ‘fraud’, and mainly due to the requirement to prove that the offender intended by committing the fraud to:

(i) to make a gain for himself or another, or(ii) to cause loss to another or to expose another to a risk of loss.

It is very difficult to prove to the Criminal standard that someone’s intention when subletting their flat was to make a gain for themselves, especially without any ability to obtain bank statements which might show rental income coming into the offender’s account, and as a large number of sublets were assumed to be done ‘cash in hand’.


Existing criminal sanctions 2In addition, there were only two main ‘frauds’ that were deemed to apply to illegal subletting: fraud by false representation under s.2 of the Fraud Act, or; fraud by failing to disclose information under s.3 of the Fraud Act.

Fraud by ‘false representation’ – s.2Frequently difficult to find a clear false representation… if the offender put down in writing to their subtenant that they owned the flat, or had authority from their landlord to sublet it, then this would be a clear lie. However, such evidence is very rare (I’ve never seen any).

Fraud by ‘failing to disclose’ – s.3The wording of the offence in the Act is that the offender, “dishonestly fails to disclose to another person information which he is under a legal duty to disclose”. This is easier to prove if your tenancy conditions require your tenants to report any changes in occupancy or absences from the property (typically for 28 days or more), or forbid parting with possession of the whole or part without consent. However, ‘dishonesty’ can be very hard to prove.


New offences under the Act: The summary-only offencesSection 1(1) –

A tenant of a dwelling-house let under a secure tenancy commits an offence if—(a) in breach of an express or implied term of the tenancy, the tenant sub-lets or parts with possession of—

(i) the whole of the dwelling-house, or(ii) part of the dwelling-house without the landlord's written consent,

(b) the tenant ceases to occupy the dwelling-house as the tenant's only or principal home, and(c) the tenant knows that the conduct described in paragraph (a) is a breach of a term of the tenancy.

In addition, Section 2(1) of the Act creates an identical offence in relation to Assured Tenancies for those Local Authorities who own/manage their stock via an ALMO, HAT or other such means involving Assured Tenancies.


New offences under the Act: The summary-only offences 2

Elements of the offence section 1(1):- “A tenant of a dwelling-house let under a secure tenancy commits an offence if… ”

o If original tenants are no longer in occupation (e.g. mother moved out with new partner, leaving adult children in the property) and the remaining ‘unlawful occupier’ sub-lets the property then they cannot be prosecuted.

o Not introductory or flexible tenancies! (Separate offence for assured tenancies in section 2)

- “… (a) in breach of an express or implied term of the tenancy, the tenant sub-lets or parts with possession of the whole or of part without the Landlord’s written consent …”o Check your tenancy conditions!

o However, Housing Act 1985 provides some implied terms:

s.91 – Assignment in general prohibited (asides from mutual exchanges or pursuant to a Court Order) s.93(1) - It is a term of every secure tenancy that the tenant—(a) may allow any persons to reside as lodgers in the dwelling-house, but(b) will not, without the written consent of the landlord, sublet or part with possession of part of the dwelling-house (and note s.94(2) – Consent shall not be unreasonably withheld)



Elements of the offence section 1(1) (continued):- “… (b) The tenant ceases to occupy the dwelling-house as his only or principal home …”

o There is a whole raft of case law in relation to the circumstances where a tenant is held to no longer occupy a property as their ‘only or principal home’:

Ujima HA v Ansah [1998] – having sublet the property and left none of his own belongings in the premises, Ansah was held to have ceased to occupy the property as his only or principal home.

But c.f. Crawley BC v Sawyer [1988] – tenant left his secure tenancy to move in with girlfriend; gas and electricity were cut off, and the following year he informed the LA that he was living with the girlfriend and that they intended to buy her flat under RTB. LA instituted possession proceedings to recover his flat, but by time of the hearing, he had split up with the girlfriend and moved back in. Judge held that the house was at all time the tenant’s principal home



Elements of the offence section 1(1) (continued):- “… and (c) The tenant knows that the conduct described in paragraph (a) is a breach of a term of the

tenancy.”o Evidence that the tenant was provided with a copy of the tenancy conditions upon sign-up will be

persuasive, as will evidence of tenant consultation/notification letters upon making any changes to tenancy conditions.

o However, there will be a possible defence open to tenants to attempt to argue that they didn’t

know that they weren’t allowed to sublet (e.g. can’t read/didn’t read tenancy conditions; was young when tenancy granted; mental health/capacity issues etc.)

o Some Boroughs have taken steps (both historically and more recently) to publicise that tenants are not allowed to sublet their council flats, both in whole or in part without permission… An option worth considering as being able to refer to such a leafleting/press campaign could again be persuasive at Court.

o Recently a number of Boroughs and Housing Associations (e.g. LB Croydon, LB Newham, Affinity Sutton, Peabody Trust) launched ‘tenancy fraud amnesties’ as part of such a publicity drive which proved successful.



Time limits for Summary only offence A prosecution for the summary only offence must be brought within 6 months from the date on which sufficient evidence to warrant proceedings came to the prosecutor’s knowledge, BUT cannot be brought more than three years after the commission of the offence, or the last date on which a continuing offence was committed.


New offences under the Act: The either way offence

Section 1(2)

A tenant of a dwelling-house let under a secure tenancy commits an offence if—(a) dishonestly and in breach of an express or implied term of the tenancy, the tenant sub-lets or parts with possession of—

(i) the whole of the dwelling-house, or(ii) part of the dwelling-house without the landlord's written consent, and

(b) the tenant ceases to occupy the dwelling-house as the tenant's only or principal home.

As with the summary-only offence, Section 2(2) of the Act also creates an identical offence in relation to Assured Tenancies for those Local Authorities who own/manage their stock via an ALMO, HAT or other such means involving Assured Tenancies.


New offences under the Act: The either way offence 2

Elements of the offence section 1(2):The only different element for this offence compared to section 1(1), is that Dishonesty is required to be proved. Dishonesty can be difficult to prove, as any who is familiar with prosecuting Housing Benefit Fraud will know!

The test to be applied is from the case of R v Ghosh (1982), and is a two stage test:1) Were the person's actions honest according to the standards of reasonable and honest people?

And if so, 2) Did the person concerned believe that what he did was, by these standards, dishonest at the time?

While there is probably no difficulty in getting past the first stage, the Defence could attempt to argue that it is not widely known that it is illegal to sublet your council flat, and as these offences are relatively new this may hold some water at Court. However, it has always been unlawful to sublet the whole (or part without permission) of a council flat, and I think most people would know and appreciate that Social Housing is there for the most needy in society as a safety net, and that as a matter of common sense it is wrong for it to be used and abused as a means to make money.


New offences under the Act: The either way offence 2

Elements of the offence section 1(2) continued:The second stage, however, is much trickier. It requires a degree of subjectivity and going-inside-the-mind of the Defendant and will depend on the facts of each case. However, with the careful cross-examination of a Defendant at trial by an experienced advocate, the Defendant’s state of mind can be unpicked. In addition, any evidence from the occupiers of a sublet property in relation to the Defendant telling them not to contact the Council (i.e. not to register to vote, register for council tax or not to claim HB etc.) would assist.


New offences under the Act: Statutory defences

The Act does provide two statutory defences to the summary only offence: 1) If the subletting was done because of violence or threats of violence made by a person living in the property or the locality towards them or their family (ie they fled the property and sublet it to a friend/relative in order to generate some money to rent a property elsewhere), and

2) If the person to whom the property was sublet would have been entitled to apply to Court for a right to occupy the property or have the tenancy transferred to them, such as a spouse, civil partner, co-habitee or child.

However, these defences do not extend to the more serious Either way offence


New offences under the Act: Penalties

Summary only offence = Fine not exceeding Level 5 on the standard scale (£5,000) Either way offence

• On summary conviction = imprisonment for a term not exceeding 6 months, a fine not exceeding the statutory maximum (£5,000), or both

• On indictment = imprisonment for a term not exceeding 2 years, an unlimited fine or both.

The Court can also, if it considers it appropriate, make an Unlawful Profit Order (more on which below)


New offences under the Act: Wide prosecution powers

The Act also provides that Local Authorities can prosecute offences under the Act whether or not they relate to the subletting of properties of which the Authority is the Freeholder/Head Landlord of, and whether or not the property is located in their local authority area. As such, if following an investigation a Local Authority gathered evidence which proved that the same person had been subletting a number of properties let under either secure or assured tenancies across the Country, then they could prosecute the Landlord for all such offences. The Act also provides that the Local Authority can prosecute for associated offences, such as aiding and abetting illegal subletting or conspiracy to illegally sublet if there is an organised or gang element to the offending.


Unlawful Profit OrdersThe new Act also provides for ‘Unlawful Profit Orders’ (“UPOs”) to be made both at the conclusion of a prosecution in the criminal courts, and/or through the civil courts, most likely as part of a possession claim based on unlawful subletting. A UPO, as one might anticipate, is an Order that the Defendant should account to their landlord for the profit made through the illegal subletting of the property. The amount to be included in a UPO is calculated as follows:

1. Determine the total amount the Defendant received through the subletting2. Deduct the amount that the Defendant paid as rent to their Landlord (including by

way of service charge) over the same period.


Unlawful Profit Orders 2In civil proceedings, before considering whether or not to make a UPO, the Claimant will need to satisfy the Court that (similarly to the grounds that need to be proved for a prosecution which were referred to above) the Defendant:

a) in breach of an express or implied term of the tenancy, sub-let or parted with possession of—

i. the whole of the dwelling-house, orii. part of the dwelling-house without the landlord's written consent,

b) ceased to occupy the dwelling-house as the tenant's only or principal home, and

c) received money as a result of the conduct described in paragraph (a). However, these elements will of course only need to be proved to the civil burden.


Unlawful Profit Orders 3The difficult part in obtaining a UPO, whether in Civil or Criminal proceedings, will be gathering sufficient evidence to prove how much money (if anything) the Defendant received for subletting the property.

This was always a problem when attempting to prosecute subletting under the Fraud Act 2006, which specifically required there to be an intention to make a gain for any offence to have been committed.

However, draft Regulations made under Section 7 of the Act are set to grant a whole swathe of new investigatory powers to Local Authorities to aid in the search for unlawful profits.


The Prevention of Social Housing Fraud (Power to Require Information) Regulations 2014

These Regulations took effect in early April 2014 and provide Local Authorities with the power to require information to be provided to them for ‘housing fraud investigation purposes’ from the following sources:

- Banks;- Companies whose business is in the whole, or in a significant part, related to providing credit to

members of the public;- Any water or sewerage undertaker;- Electricity/Gas suppliers, and;- Providers of any telecommunications services.

Information can now be requested from these companies both in relation to a person who is suspected of committing, having committed or intending to commit social housing fraud or a member of their family. These new powers are near identical to those which presently exist for investigating Housing Benefit fraud offences as set out in s.109B of the Social Security Administration Act 1992. They enable Local Authorities to obtain copies of suspects’ bank statements (which may contain evidence of regular rental income being received); their credit card, personal loan or mortgage statements, and; details of utilities accounts held by them and/or details of the names of the account holders at the address of the sublet property. These should provide useful evidence to support a case of an illegal sublet having occurred in the first place.


The Prevention of Social Housing Fraud (Power to Require Information) Regulations 2014 2

In terms of information that can be required from telecommunications service providers, this is limited to ‘communications data’; this does not mean the content of any communications sent or received by a suspect, but the ‘who, when and where’ of those communications, such as a telephone billing or subscriber details. In addition, the Regulations usefully provide that a subscriber whose details are required can be identified by reference to just their telephone number or email address. For example, if the subtenant occupying the property agrees to provide evidence in support of the council’s case about who sublet the property to them, and provides copies of text messages or emails from their landlord saying, for example, “£200 rent received today, thank you”, then you would be able to ask the telecommunications provider to give you details of the customer who holds that mobile telephone number/email address, in order to confirm that what the subtenant has told you is true, and that the message was sent to them by the suspect.


The Prevention of Social Housing Fraud (Power to Require Information) Regulations 2014 3

These powers can, however, only be carried out by ‘Authorised Officers’, who must be either employees of your local authority, or a person employed by another local authority or joint committee which is carrying out housing fraud investigation functions on behalf of your authority. The authorisation must be in writing and be provided to the authorised officer as evidence of their entitlement to exercise powers under the regulations. The regulations state that the authorisation can only be given by the Head of Paid Service (Chief Exec) or the Chief Finance Officer.


Application of New Investigatory Powers to Cold Cases

While the new offences are not retroactive, the Act does state that the powers set out in the Regulations can be used to obtain information for any ‘housing fraud investigation purposes’, which include not only offences under the new Act, but also specifically include offences under the Fraud Act 2006 relating to:

– The unlawful sub-letting or parting with possession of the whole or part of a dwelling-house;

– A fraudulent application for an allocation of accommodation or assistance under Parts 6 and/or 7 of the Housing Act 1996; or

– Fraudulent claims to exercise the right to buy under Part 5 of the Housing Act 1985, the right to acquire under section 16 of the Housing Act 1996, or the right to acquire under section 180 of the Housing and Regeneration Act 2008.

As such, these new investigatory powers can be used for older, sub-letting offences, using the pre-existing Fraud Act offences referred to above – review any cold cases you may have!


Sharing Information Gathered Under the Regulations

It is anticipated that information gathered under the Regulations will not only be useful for proving a criminal offence has been committed, but also for proving that a suspect has breached their tenancy conditions and/or parted with possession of the property for the purposes of taking possession proceedings against the suspect as well.

While the Regulations are clear that this information can only be obtained in connection with criminal ‘social housing fraud’ offences, once the information has been obtained it would be held by the investigating authority as ‘personal data’ (as defined by the Data Protection Act 1998). Although the DPA generally places restrictions on the sharing/disclosure of personal data, the Act does provide for exemptions, including an exemption for information required in connection with legal proceedings, under s.35. As such, Councils should be able to share any such information with their (or other) Housing Departments without fear of any DPA repercussions. However, if the initial data providers (the banks and utilities companies etc.) place any restrictions on the data they disclose, then you may first need to obtain their permission before sharing it, but this will need to be addressed on a case-by-case basis.


Thank you for listening

Any questions? Please contact:

Simon KielySharpe Pritchard LLP

[email protected] 020 7405 4600

mailto:[email protected]


Disclosure and Unused Material Simon Kiely

Solicitor, Sharpe Pritchard LLP


Topics to be covered

1. Background

2. Legal Framework

3. Initial Details of the Prosecution Case

4. Primary Disclosure and the Disclosure Test

5. Sensitive/Non-sensitive Material

6. Consequences of Non-disclosure

7. Defence, Secondary and On-going Disclosure


Background

• Fundamental starting point is the Right to a Fair Trial (Article 6). Disclosure plays a key role in ensuring compliance with the Right to a Fair Trial, and that a Defendant’s Human Rights are protected.

• In addition, there is the Right to Silence and against Self-Incrimination – no initial duty for Defendant to give disclosure or put forward a Defence before trial.

• 2 (or 3) disclosure duties on the prosecution:

1. Primary Duty

2. “Secondary” Duty, and

3. The On-going Duty


Legal Framework

• Criminal Procedure and Investigations Act 1996 (as amended by the CJA 2003) – “the CPIA”

• The Code of Practice under Part II of the CPIA 1996 (Brand new version to be published shortly… Statutory Instrument published on 29 January 2015 (see http://www.legislation.gov.uk/uksi/2015/9780111128190/made) which states that it will come into force once approved by the House of Lords. Have been informed by MoJ that new version will be published online soon. Until then, the old version is in Stone’s (1.2827)

• Criminal Procedure Rules 2014 (rs 10 and 22) • Attorney General’s Guidelines on Disclosure 2013 (

https://www.gov.uk/government/publications/attorney-generals-guidelines-on-disclosure-2013)

• Judicial Protocol on the Disclosure of Unused Material in Criminal Cases (http://www.judiciary.gov.uk/publications/protocol-unused-material-criminal-cases/)

http://www.legislation.gov.uk/uksi/2015/9780111128190/made

https://www.gov.uk/government/publications/attorney-generals-guidelines-on-disclosure-2013

http://www.judiciary.gov.uk/publications/protocol-unused-material-criminal-cases/


Initial Details of the Prosecution Case

Rule 10.2 of the Criminal Procedure Rules“Providing initial details of the prosecution case10.2.—(1) The prosecutor must serve initial details of the prosecution case on the court officer—

(a) as soon as practicable; and(b) in any event, no later than the beginning of the day of the first hearing.

(2) Where a defendant requests those details, the prosecutor must serve them on the defendant—

(a) as soon as practicable; and(b) in any event, no later than the beginning of the day of the first hearing.

(3) Where a defendant does not request those details, the prosecutor must make them available to the defendant at, or before, the beginning of the day of the first hearing.”


Initial Details of the Prosecution Case 2

Rule 10.3 of the Criminal Procedure“Content of initial details10.3. Initial details of the prosecution case must include—(a) a summary of the evidence on which that case will be based; or(b) any statement, document or extract setting out facts or other matters on which that casewill be based; or(c) any combination of such a summary, statement, document or extract; and(d) the defendant’s previous convictions.”


Primary Duty of Disclosure

Primary Duty of Disclosure (ss.1 and 3 CPIA)The Primary Duty of Disclosure applies to:a) any case where the Defendant pleads not guilty to a summary-only offence and the matter proceeds to trial in the Magistrates’ Court, b) case against a person over 18 years of age for an either way offence which is sent for summary trial in the Magistrates’ Court, and c) a case against a person under 18 years of age for an indictable-only offence sent for summary trial in the Magistrates’/Youth Court.

While these rules initially only relate to matters proceeding to trial in the Magistrates’ Court, if the Defendant pleads not guilty and the matter is transferred to the Crown Court these obligations bite once the matter is set down for trial (i.e. after your Preliminary or Plea and Case Management hearing, depending on how your case progresses).

There is no fixed time-limit for compliance, but Primary Disclosure must be provided as soon as reasonably practicable.


The Disclosure Test: What are you required to provide?

The prosecution should keep a record all information gathered during the course of an investigation. If the material is going to be used as evidence to prove the case, then this can be recorded in a Schedule of Used Material. If the material is not going to be used to prove the case, then it must either be recorded in a Schedule of Non-sensitive Unused Material, or a Schedule of Sensitive Unused Material (more on which to follow).

Different officers in the investigation have different roles to play in disclosure. The Code of Practice indicates such records should initially be maintained by either the Investigating Officer or a specific Disclosure Officer (!)

Best practice is to start keeping these records from the start of the investigation, rather than having to go through all gathered material afterwards… Little and often!

The Sensitive Unused Material Schedule will not be served on the Defence, but the Non-sensitive Unused Material Schedule will. However, not all of the material recorded in that Schedule will need to be disclosed as part of Primary Disclosure (if at all)


The Disclosure Test: What are you required to provide? 2

When complying with the Primary Duty, the prosecutor must (s.3(1) CPIA): “(a) Disclose to the accused any prosecution material which has not previously been disclosed … and which might reasonably be considered capable of undermining the case for the prosecution against the accused or of assisting the case for the accused, or

(b) give to the accused a written statement that there is no material of a description mentioned in paragraph (a)”

• Quite a finely balanced test – especially if there has been no indication whatsoever from the Defendant of what their Defence is or the basis upon which they consider they are not guilty.


Sensitive/Non-sensitive Material

Sensitive material is that which it is reasonably considered by the Investigating Officer/Disclosure Officer and the Prosecutor which it would not be in the public interest to disclose.

Consideration should always be given as to whether any sensitive material can be redacted of any personal or other information which is of particular concern, with the remaining information disclosed if it passes the disclosure test.

The Code of Practice under Part II of the CPIA provides useful guidance at Paragraph 6.12 on points to consider when assessing whether material is sensitive.

If unsure, reference should also be made to Chapter 8 of the CPS disclosure manual (

http://www.cps.gov.uk/legal/d_to_g/disclosure_manual/disclosure_manual_chapter_8/) which contains more useful guidance

http://www.cps.gov.uk/legal/d_to_g/disclosure_manual/disclosure_manual_chapter_8/


Sensitive/Non-sensitive Material 2

Relevant examples of sensitive material which it would not be in the public interest to disclose include: Material given in confidence; Material relating to the identity, activities or private lives of informants/witnesses who may be

in danger if their identities are revealed, or which might threaten the public confidence that proper measures will be taken to protect witnesses from intimidation and harassment;

Material revealing, either directly or indirectly, techniques and methods relied upon in the course of a criminal investigation, for example covert surveillance techniques, or other methods of detecting crime;

Material which might threaten the safety of those who comply with their statutory obligation to report suspicious financial activity

Material which relates to a child or young person and which has been generated by a local authority social services department, an Area Child Protection Committee or other party contacted by an investigator during the investigation;

Material which may threaten the freedom of investigators and prosecutors to exchange views frankly about casework.


Sensitive/Non-sensitive Material 3

If there is any material which both passes the disclosure test and is genuinely sensitive, and cannot be partially redacted to remove any sensitive material whilst still retaining the information which either undermines the prosecution case or assists the Defendant, then your only options are to either abandon the prosecution or make an application to Court for a Public Interest Immunity (PII) ruling.

•There are three types of PII application which can be made:1. An ‘on notice’ application, where the material is categorised and described generally, the

application form served on the Defence, and a contested hearing held in open court (this is the most usual type of application);

2. An ex parte ‘on notice’ application, where the application is served on the Defence with as much information about the material as is possible without disclosing any sensitive information, and where the Defence are given the opportunity to make representations in writing in advance of the hearing, but where the application is heard in the absence of the Defence.

3. An ex parte ‘without notice’ application, where no notice is given in advance, and the matter is heard without the Defendant present (the least common type of application).


Consequences of Non-disclosure

If the prosecution fail to comply with their disclosure obligations there are a number of potential consequences, depending on the reasons for non-compliance:• The Defendant may raise a successful abuse of process argument at the trial;• If the Defendant is on remand, the prosecutor may be unable to argue for an extension

of the custody time limits;• The Defendant may be released from the duty to make defence disclosure (if applicable);• Costs may be awarded against the prosecution for any wasted costs incurred by the other

side through the delay/non-compliance; • The Court may decide to exclude some or all prosecution evidence from trial; • On appeal any conviction may be found unsafe; and• Disciplinary proceedings may be taken against the prosecutor or investigating officer.


Defence, Secondary and On-going Disclosure

If your case is proceeding to trial in the Magistrates’ Court, then there is no obligation on the Defendant to file a Defence Case Statement (“DCS”) or give any disclosure of their own.

However, for matters proceeding to trial in the Crown Court, the Defence are obliged to file a DCS pursuant to s.5 CPIA within 28 days of prosecution Primary Disclosure being complied with (as per Regulation 2(3) of the of the Criminal Procedure and Investigations Act 1996 (Defence Disclosure Time Limits) Regulations SI 2011/209).

Following the service of a DCS, then as soon as reasonably practicable the prosecutor must review the unused material again and reassess whether any of it now meets the disclosure tests in light of the information contained within the DCS, or write to confirm that there is no additional material, pursuant to s.7A(5) CPIA. An updated copy of the Non-Sensitive Unused Material Schedule confirming that all documents have been assessed for Secondary Disclosure and whether any have been disclosed should be provided to the Defence at this stage in either event.


Defence, Secondary and On-going Disclosure 2

If you take the view that no further documents are disclosable at this stage, then the Defence are entitled to make an application to the Court for specific items on the Non-Sensitive Unused Material Schedule be to be disclosed if they think that the description of the material on the schedule suggests it may assist their case or undermine your case.

Don’t forget that even once Secondary Disclosure has been complied with, disclosure remains a continuing obligation!

If additional material is received during the course of the case which is not going to be used at trial, then you need to subject it to the same tests as above, ensure that the Unused Material Schedules are updated accordingly, and provide the updated schedules to the other side.


Thank you for listening

Any questions? Please contact:

Simon KielySharpe Pritchard LLP

[email protected] 020 7405 4600

mailto:[email protected]

Documents

Www.emlawshare.co.uk Prevention of Social Housing Fraud Act 2013 Simon Kiely Solicitor, Sharpe Pritchard LLP