The evidence relating to intentional homelessness is evidence bearing on the reason why the applicant is homeless. The local authority’s investigation duties relate to homelessness, not unemployment. An appreciation of local job prospects is relevant only insofar as it explains why it is that the applicant is homeless. It is not necessarily relevant to the applicant’s homelessness. There may, or may not, be a sufficient linkage between them. The duty to investigate is to make necessary enquiries. It is not a duty to make all possible enquiries. So held in Ciftci v Haringey LBC (2021) EWCA Civ 1772.

Hajjaj v Westminster and Akhter v Waltham Forest (2021) EWCA Civ 1688 address the use by local housing authorities of the private rented sector in accordance with Sections 148 and 149 of the Localism Act 2011 to bring to an end the main homelessness duty under Section 193(2) in Part 7 of the Housing Act 1996. The main question was in what circumstances accommodation should be regarded as not suitable to form the subject of a valid private rented sector offer (PRSO). This is governed by Article 3 of the Homelessness (Suitability of Accommodation) (England) Order 2012. Accommodation shall not be regarded as suitable where one or more of ten listed conditions applies.

Bean LJ says, at para 70, that suitability is a “multi-faceted concept”. It includes size, location, accessibility, if the applicant is elderly or disabled, as well as the physical condition and other matters. The authority must be satisfied that none of the ten bars to suitability established by Article 3 applies. They must be “satisfied on the basis of evidence rather than assumptions”. He adds, at para 72, that satisfactory hearsay evidence may be enough.