W v London Borough Of Haringey

The review decision was made on behalf of Haringey by Mr Minos Perdios ("the reviewer") He is an employee of Home Reviews Ltd., a company instructed by Haringey to carry out homelessness reviews on its behalf.

a. The test for vulnerability under section 189(1)(c) is whether an applicant is "significantly more vulnerable than ordinarily vulnerable" as a result of being rendered homeless (para. 53).

b. The comparator for the purposes of that test is with an "ordinary person if made homeless" and not an "ordinary actual homeless person" (para. 58).

c. The previously accepted description of the appropriate comparator as expressed by Hobhouse LJ in R v Camden London Borough Council, Ex p Pereira (1999) 31 HLR 317 ("Pereira" )(whether the applicant "when homeless [will be] less able to fend for himself than an ordinary homeless person") was ambiguous and imprecise (paras. 49 and 53).

d. Expressions such as "street homelessness" and "fend for oneself' may be useful in discussions but can be dangerous if employed in a document which is intended to have legal effect (paras. 40 to 42).