In R (DF) v Essex County Council (2024) EWCA Civ 1545 the Court of Appeal confirms that a child who is homeless for the purposes of Section 175 of the Housing Act 1996 will not necessarily require accommodation for the purposes of Section 20 of the Children Act 1989. The Children Act question whether a child requires accommodation is to be answered as a matter of factual evaluation, applying that phrase in its natural and ordinary meaning, and without reference to the homelessness definition in the Housing Act.
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