Summary: the Council failed to properly assess Mr B’s homeless application, failed to issue him with a personal housing plan or a decision as to which duty the Council had accepted, delayed offering him interim accommodation, failed to provide him with suitable accommodation, failed to respond to some of his representative’s communications and included incorrect information in a complaint response. An apology, payment to Mr B, reminders, training for officers and a review of the process for identifying properties for homeless applicants is satisfactory remedy.

The complaint

1. The complainant, whom I shall refer to as Mr B, complained the Council:
• failed to assess his homeless application correctly, failed to issue a personal housing plan (PHP) and failed to issue a decision letter telling him whether the Council had accepted a prevention or relief duty;
• failed to provide him with interim accommodation until he was evicted from the property despite knowing it was unaffordable for him to remain in;
• provided unsuitable interim accommodation when he was evicted and, in doing so, failed to consider its public sector equality duty;
• failed to respond to his or his representative’s various communications; and
• delayed responding to his complaint and relied on inaccurate information in that complaint response.
2. Mr B says the Council’s actions have caused him significant distress and meant he incurred additional rent arrears and court costs before being evicted by bailiffs.

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The Ombudsman’s role and powers

3. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused an injustice, we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
4. If we are satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(i), as amended)

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How I considered this complaint

5. As part of the investigation, I have:
• considered the complaint and Mr B's comments;
• made enquiries of the Council and considered the comments and documents the Council provided.
6. Mr B and the organisation had an opportunity to comment on my draft decision. I considered any comments received before making a final decision.

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What I found

What should have happened

7. Part 7 of the Housing Act 1996 (the Act) and the Homelessness Code of Guidance for Local Authorities (code of guidance) set out councils’ powers and duties to people who are homeless or threatened with homelessness.
8. The Act says someone is threatened with homelessness if, when asking for assistance from the council, he or she is likely to become homeless within 56 days or he or she has been served with a valid Section 21 notice which will expire within 56 days. Serving of a section 21 notice is a landlord’s first step in evicting a tenant.
9. The Act says where a housing authority has reason to believe a person asking the council for help with accommodation may be homeless or threatened with homelessness, it must make enquiries about whether the person is eligible for help and what, if any, duties are owed to that person. These enquiries take the form of an assessment undertaken by the council and should usually include an in-person interview. When a housing authority has completed its inquiries it must notify the applicant in writing of its decisions.
10. Assessments must include details of the circumstances that have caused the applicant to either become homeless or be threatened with homelessness, the applicant’s housing needs and what support they would need to have and keep suitable accommodation. The Act is clear an applicant should not be treated as having accommodation unless it is reasonable for them to occupy it.
11. When considering whether it is reasonable for an applicant to continue to occupy their accommodation the council should take into account the affordability of that accommodation. (The Homelessness (Suitability of Accommodation) Order 1996) Council’s must, in particular, take account of:
• (a)the financial resources available to the applicant (including savings and capital);
• (b)the costs of the accommodation;
• (c)maintenance payments (to a spouse, former spouse or in respect of a child); and,
• (d)their reasonable living expenses
12. The code of guidance says housing authorities will need to consider whether the applicant can afford the housing costs without being deprived of basic essentials such as food, clothing, heating, transport and other essentials specific to their circumstances. Housing costs should not be regarded as affordable if the applicant would be left with a residual income that is insufficient to meet these essential needs.
13. Throughout any period an applicant remains in occupation whilst the landlord pursues possession action, the housing authority should keep the reasonable steps in the applicant’s PHP under regular review, and maintain contact with the tenant and landlord to see if there is any change in circumstances which affects whether or not it continues to be reasonable for the applicant to occupy.
14. Where applicants are threatened with homelessness and eligible for assistance, housing authorities must take reasonable steps to help prevent their homelessness. This is called the prevention duty.
15. Under the prevention duty councils are required to help applicants secure accommodation but do not have to secure such accommodation themselves. The prevention duty comes to end in particular identified circumstances that include where the applicant becomes homeless but where a landlord has served a valid section 21 notice. The council is required to notify the applicant of the end of this duty and the reasons for this and the applicant may ask for a review of this decision.
16. Councils have a relief duty where they are satisfied that an applicant is homeless (as opposed to threatened with homelessness) and eligible for assistance. Under the relief duty the council is required to take reasonable steps to help the applicant secure accommodation that will be available for at least 6 months. Again, it does not have to secure the accommodation itself though it may choose to do so. When the council decides the applicant is in priority need and is not intentionally homeless the relief duty ends after 56 days. The council must then decide if a main housing duty is owed.
17. If, after completing an assessment, the council does consider it owes the applicant a duty it must draw up a PHP with the applicant to either prevent or relieve their homelessness. This details the actions both the council and the applicant will take to try to resolve the threatened or actual homelessness. The PHP must be kept under review.
18. If homelessness is not successfully prevented or relieved the council will owe the main housing duty to applicants who are eligible, have a priority need for accommodation and are not intentionally homeless. Households with priority need if homeless include those who are vulnerable. Councils may perform the main housing duty by providing accommodation itself, securing accommodation from someone else or helping the applicant to find their own secure accommodation.
19. A council must provide interim accommodation if (and as soon as) it has reason to believe a person (or household) may be homeless, eligible and in priority need.
20. The code of guidance says the Secretary of State considers it is highly unlikely to be reasonable for the applicant to continue to occupy a property beyond the date on which the court has ordered them to leave the property and give possession to the landlord.
21. The code of guidance says housing authorities should not consider it reasonable for an applicant to remain in occupation up until the point at which a court issues a warrant or writ to enforce an order for possession.
22. The code of guidance says housing authorities should ensure homeless families and vulnerable individuals who are owed a section 188 interim accommodation duty or section 193(2) main housing duty are not evicted through the enforcement of an order for possession due to failure by the authority to make suitable accommodation available to them.
23. All accommodation provided under Part 7 of the Act must be suitable for the applicant and their household. Housing authorities will need to consider carefully the suitability of accommodation for households with particular medical and/or physical needs. Physical access to and around the home, space, bathroom and kitchen facilities, access to a garden and modifications to assist people with sensory loss as well as mobility needs are all factors which might need to be taken into account.

What happened

24. Mr B was living with his mother in a private rented property and succeeded to her tenancy in December 2021 when she sadly died. The rent for that property was £2,000 per month. Mr B applied for housing costs as part of his universal credit application. However, due to the difference between the rent charged and the local housing allowance Mr B had to cover more than £850 from his own income. Mr B is on benefits and did not consider the property affordable. He therefore fell into rent arrears and his landlord served him with a notice of seeking possession under section 8 of the Housing Act 1988, requiring possession on 28 March 2022.
25. Mr B approached the Council for help in March 2022. Mr B’s representative told the Council Mr B was vulnerable and asked for an early appointment as he considered it unreasonable for Mr B to continue to occupy the property given it was unaffordable. Mr B’s representative suggested the Council might award a discretionary housing payment to enable Mr B to stay in the property until he could secure alternative accommodation in the private sector. Mr B’s representative said if that was not possible the Council should provide interim accommodation.
26. The Council told Mr B’s representative it could not help with the arrears given Mr B would be unable to cover the rent and would quickly fall back into arrears. The Council suggested Mr B expand his choice of areas although it noted that would still require a wait of several months which would be too long in the current circumstances. The Council said it had asked its property negotiator to look for a one-bedroom property for Mr B.
27. The Council carried out an assessment on 26 April 2022. The Council did not issue a decision letter following that assessment and did not draw up a PHP.
28. Mr B received an offer of a housing association property in July 2022. However, the housing association later withdrew that offer as it did not consider the property suitable for Mr B.
29. Mr B’s representative contacted the Council about that on 9 August. Mr B’s representative told the Council Mr B did not have a defence against the possession order due in court later that month and asked why the Council had not issued a PHP or a decision on whether the property was reasonable for Mr B to continue to occupy. Mr B’s representative asked the Council to provide interim accommodation as Mr B’s property was unreasonable for him to continue to occupy. Mr B’s representative invited the Council to issue a section 184 decision if it disagreed. In response the Council said it would contact the housing association about the withdrawal of the property. The Council did that but the housing association did not change its view.
30. Mr B’s representative contacted the Council again on 12 and 16 August to remind it about the court proceedings taking place on 17 August. He raised concerns about the level of debt Mr B would face if he remained in occupation pending the execution of the warrant. The Council told the representative if possession was granted the Council would accept the relief duty and continue to look for suitable accommodation and, if all else failed, offer bed-and-breakfast which the Council was trying to avoid.
31. Mr B received a possession order on 17 August which required him to give possession of the property to the landlord on or before 14 September and pay the outstanding rent arrears. The order stated Mr B would have to pay £65.75 per day from 19 August until possession of the property was given to the landlord.
32. Mr B’s representative provided the Council with a copy of that order on 24 August and asked for a response to his previous emails. He reminded the Council any interim accommodation should be suitable for Mr B’s needs.
33. The possession order expired on 14 September.
34. Mr B’s representative chased the Council on 20 September. He told the Council the possession order had given Mr B until 14 September to vacate the property, arrears were increasing each day and the Council had failed to provide a full assessment. He requested a response within five days.
35. On 23 September the Council considered Mr B’s case and decided he was vulnerable and in priority need. The Council decided he needed ground floor accommodation if there was no lift and any floor with a lift.
36. On 26 September the Council responded to the representative’s email of 20 September to advise of the action taken. The Council said it was seeking an update on interim accommodation arrangements and would follow-up. The Council said at the time of Mr B’s application the Council considered he had the financial means to pay the rent as his savings would cover the difference between the amount he received from universal credit and the contractual rent amount to enable him to cover it for a further six months. The Council therefore said it did not consider the homeless relief duty was accepted. The Council accepted a section 184 (not homeless within 56 days) decision should have been issued at the time but was overlooked as the Council concentrated on trying to help Mr B identify suitable alternative accommodation. The Council said finding suitable accommodation given Mr B’s mobility issues and geographical areas he could consider made that more difficult than anticipated. The Council said it would update the representative on interim accommodation arrangements once the position had been established.
37. On 27 September Mr B received a notice of eviction to be executed on 10 November.
38. Mr B’s representative contacted the Council again on 28 September. Mr B’s representative raised concerns about the lack of progress and asked the Council to contact Mr B to set out the next steps. He raised concerns again about the Council’s failure to issue a decision letter on Mr B’s case and provide interim accommodation. He said Mr B had removed all the furniture in anticipation of the eviction on the instruction of the landlord which meant his only means of manoeuvring safely within the property had gone which further meant the property was unreasonable to continue to occupy. He also pointed out the Council could trigger the public sector equality duty and prioritise Mr B for suitable housing.
39. Mr B’s representative chased the Council on 5 October. He pointed out the code of guidance made clear it was unreasonable for a homeless applicant to remain in occupation of the property beyond the date on which a court had ordered them to leave. He chased the Council again on 19 October.
40. The Council contacted the complainant’s representative on 26 October and apologised for the delay. The Council said it was trying to secure accommodation to meet Mr B’s needs within the geographical area he would consider and that was separate to any arrangements to be made for interim accommodation.
41. In response Mr B’s representative pointed out Mr B was severely disabled, subject to substantial housing related debt, distressed following the loss of his mother and lacked the ability to manoeuvre freely in the property occupied as he had to get rid of all the furniture in anticipation of a move. He raised concerns with less than two weeks until the eviction there was no indication suitable accommodation had been secured on an interim basis or otherwise and nobody had met with Mr B to complete a personal assessment of his needs. He raised concerns about the lack of communication from the Council. He asked the Council to communicate the next steps to Mr B and confirm suitable accommodation would be secured as a matter of priority.
42. Mr B’s representative chased the Council again on 7 and 9 November raising concerns about the lack of progress as Mr B was due to be evicted on 10 November. In response the Council told Mr B’s representative it would provide interim accommodation and had requested self-contained accommodation to meet Mr B’s health needs.
43. Mr B was evicted by bailiffs on 10 November and the Council provided him with interim accommodation in a shared facility. The Council told Mr B’s representative that and said it would move Mr B to more suitable accommodation when it became available.
44. Mr B contacted the Council on 30 November to find out how much longer he would remain in shared accommodation. Mr B said he had to wash in the small kitchen sink as he could not stand in the shower due to his mobility issues. Mr B also said he was finding it hard to walk around and therefore spent most of his time in his room. The Council said it could not provide a timescale.
45. On 8 December an organisation which works in partnership with local authorities and housing associations told the Council it had three one-bedroom flats available for applicants over 55 that were taking medication and may need extra care around that. It asked the Council whether it had any applicants that fit that criteria. The Council put Mr B forward.
46. On 19 December the Council offered Mr B a change of accommodation to ground floor self-contained temporary accommodation. Mr B declined that as it was still temporary accommodation.
47. Mr B accepted the tenancy for a housing association property on 22 December and moved in on 28 December.

Complaint correspondence timeline

48. In December 2022 Mr B’s representative put in a complaint. The Council responded on 10 January 2023. In that complaint response the Council accepted it had not issued a section 195 letter or PHP. The Council said though it had not considered Mr B homeless in April 2022 as he had savings to cover the difference between the contractual rent and the local housing allowance for a six-month period. The Council said due to the lack of suitable properties its view is applicants are better off staying where they are for as long as possible while they continue to seek alternative accommodation. The Council noted it had provided Mr B with shared accommodation as that was all that was available when Mr B was made homeless. The Council said it had reorganised its service to ensure one officer deals with a case from start to finish to prevent confusion in future. The Council said it considered it had taken into account Mr B’s medical conditions when offering him accommodation on the ground floor. The Council apologised for the lack of communication and failure to follow up on assessments with a written PHP.
49. Mr B’s representative expressed dissatisfaction with that response on 31 January. The Council responded to the complaint at stage two on 14 April and apologised for the delay. The Council said it had located a property for Mr B which he had now moved into and said it had paid rent in advance of £1,500 and £300 for moving costs. The Council said it considered that a suitable resolution alongside a one-off payment of £100 for Mr B’s time and trouble and frustration.
50. Mr B’s representative contacted the Council again on 17 April. He said Mr B had never received any rent in advance or moving costs and no such payment had been made to the accommodation provider. He invited the Council to amend its complaint response on that point.

Analysis

51. Mr B says the Council failed to assess his homeless application correctly, issue a PHP or a decision letter telling him whether the Council had accepted a prevention or relief duty. Mr B says because the property he was living in was unaffordable the Council should have recognised that, accepted the relief duty and provided him with interim accommodation in April 2022. Mr B says because the Council failed to do that he was left to live in unaffordable accommodation for eight months longer than he should have which led to him incurring significant rent arrears, court costs and facing eviction by bailiffs.
52. The starting point is the initial assessment the Council completed in April 2022. The Council says at that point it considered Mr B had sufficient savings to cover the shortfall in rent for around five months and was therefore not homeless. The Council says it therefore concentrated its efforts on seeking to identify suitable alternative accommodation for Mr B. None of that reasoning is recorded in the assessment the Council completed in April 2022. Although that assessment referred to the fact universal credit only covered £1,150 of the £2,000 monthly rent Mr B was liable for there is no reference in the assessment to whether the Council considered Mr B’s property reasonable for him to continue to occupy. The Council should have considered that point and there is no evidence it did so at the time of the April 2022 assessment. If the Council had considered Mr B had sufficient funds to maintain the tenancy for a short period at that point it should, in any event, have issued a letter telling Mr B it had accepted the prevention duty rather than the relief duty. The Council also failed to do that. Failure to assess whether it was reasonable for Mr B continue to occupy his property and failure to issue a decision letter is fault. That meant Mr B was denied his right of appeal.
53. In addition, the Council should have completed a PHP in April 2022. That PHP would have set out the steps Mr B was required to take to address his homelessness as well as any steps the Council agreed to take. I consider this an important omission because it meant between April and September 2022 Mr B had no guidance about what he or the Council were expected to do to address his housing situation. That is a serious injustice.
54. The Council also failed to complete a PHP in September 2022 when the Council accepted the relief duty and failed to issue a decision letter at that point. Failure to complete a PHP and send Mr B a letter to tell him the Council had accepted the relief duty in September 2022 is fault.
55. Mr B says the Council should have decided in April 2022 it was not reasonable for him to continue to occupy the property he was living in given he would have had to cover an additional £850 per month out of his own income and he is on benefits. However, had the Council carried out a proper assessment in April 2022 it could have taken into account the level of Mr B’s savings when reaching its decision. At that point Mr B had more than £10,000 in savings. The Council would have been entitled to take that into account, although it would also have had to take into account the fact Mr B already had £6,000 in rent arrears at that point.
56. I could not say, on the balance of probability, if the Council had properly considered the case in April 2022 it would have accepted it was not reasonable for Mr B to continue to occupy his property while looking for alternative accommodation or that it would have provided him with interim accommodation. I consider though Mr B has suffered a significant injustice as he is left with some uncertainty about whether his situation would have been different had the Council properly considered the case. I also consider Mr B has suffered an injustice as he missed out on the opportunity to appeal the Council’s decision to accept the prevention rather than relief duty.
57. Mr B says the Council failed to provide him with interim accommodation until he was evicted from the property. Mr B says the Council should not have told him to stay in the property until the possession order expired given the Council knew the property was unaffordable. Mr B says this meant he incurred additional court costs and had to suffer the distress of bailiffs evicting him.
58. As I said earlier, I could not say if the Council had considered the case properly in April 2022 it would have accepted the property was unreasonable for Mr B to continue to occupy. I therefore could not say Mr B missed out on interim accommodation from April 2022, although he is left with some uncertainty. However, I am concerned that despite the Council accepting the relief duty in September 2022 it failed to provide Mr B with interim accommodation even though it knew the possession order expired on 14 September 2022.
59. As I said in paragraphs 20 and 21 the code of guidance is clear the Council should not consider it reasonable for an applicant to remain in occupation until the court issues a warrant or writ to enforce an order for possession and it is highly unlikely reasonable for an applicant to continue to occupy a property beyond the date on which the court has ordered them to leave. I therefore consider the Council at fault for failing to provide Mr B with interim accommodation in September 2022. That caused Mr B a significant injustice as he incurred additional costs and rent arrears and had to face bailiffs evicting him onto the street when he should not have had to go through that. In addition, it is clear Mr B was struggling to maintain safe occupancy of the property given most of his belongings had been moved out pending his eviction. That is particularly important in Mr B’s case as he has mobility issues which mean he relies on leaning on furniture when moving around his property. I am satisfied Mr B would not have had to experience any of that from September 2022 if the Council had considered his case properly.
60. In reaching that view I appreciate the Council has a shortage of self-contained accommodation for those with medical needs. The Council therefore says it is often better for a homeless applicant to remain in their own accommodation as long as possible as it is likely the Council will have to provide bed-and-breakfast or shared accommodation. I appreciate the pressures the Council is under. Nevertheless, failing to have suitable accommodation available and leaving a homeless applicant to remain in accommodation until bailiffs evicted him is not in accordance with the code of guidance and is fault.
61. Mr B says the Council provided unsuitable interim accommodation when he was evicted. Mr B says the Council knew and accepted he needed self-contained accommodation due to his medical conditions but still placed him in shared accommodation in November 2022. The Council accepts the accommodation provided in November 2022 was unsuitable but says it was the only accommodation available on the day Mr B was evicted.
62. As I said earlier, I understand the pressures the Council is under in terms of identifying suitable accommodation for homeless applicants. However, in this case the Council had known from April 2022 Mr B would not be able to stay in his property long term. The Council also had from September 2022, when it accepted the relief duty, to find suitable self-contained accommodation for Mr B. Providing Mr B with what the Council knew to be unsuitable accommodation is therefore fault.
63. I am satisfied though the Council offered Mr B self-contained accommodation on 19 December. Mr B refused that accommodation because it was still temporary accommodation and, in any event, he secured a permanent social tenancy and moved into it on 28 December. As the Council had offered Mr B self-contained accommodation on 19 December I could not say Mr B stayed in unsuitable accommodation between 19 December and 28 December due to fault by the Council. Instead I consider Mr B had to stay in unsuitable accommodation between 10 November 2022 and 19 December 2022 due to fault by the Council. To remedy that injustice I recommended the Council pay Mr B £250. The Council has agreed to my recommendation.
64. Mr B raised concerns about the Council failing to consider its public sector equality duty when dealing with his case. Under the terms of its equality policy the Council is committed to deliver services which are accessible to all and tailored to the diverse and individual needs of the community. I am not satisfied the Council did that in this case as it failed to provide Mr B with interim accommodation between September and November 2022 and, when it provided interim accommodation, provided accommodation it knew to be unsuitable. That is fault.
65. Mr B says the Council failed to respond to his or his representative’s various communications. Mr B is referring here to a representative from the citizens advice bureau who was dealing with the Council on his behalf. The Council says it responded to some of the emails from the representative but as it received 22 emails over a six-month period this made it impossible to respond to every email.
66. I understand the Council’s homelessness officers are under significant pressure. However, I would expect the Council to have responded to emails from Mr B’s representative, particularly as those emails raised significant concerns about how the Council was dealing with Mr B’s case. I do not consider though 22 emails over a six-month period a huge amount. Some of those emails were also chasing responses to previous emails. Failure to respond to those emails is fault and likely meant the Council missed further opportunities to identify issues with how it had dealt with Mr B’s case. To remedy that I recommended the Council apologise both to Mr B and to his representative. The Council has agreed to my recommendation.
67. Mr B says the Council delayed responding to his complaint and relied on inaccurate information in the complaint response. The Council accepts it delayed responding to the complaint and apologised. However, in the stage two complaint response the Council refers to providing Mr B's landlord with £1,500 rent in advance and £300 towards moving costs. As Mr B's representative has pointed out, that information is incorrect. Mr B's representative invited the Council to correct that information and there is no evidence the Council responded to that.
68. I am satisfied the information about the £1,800 referred to in the Council's stage two complaint response is incorrect. When corresponding with the Ombudsman the Council has accepted the £1,800 was paid as a finders fee to the organisation acting as a go-between for the Council and social housing providers. I am therefore satisfied that £1,800 was not paid to Mr B's landlord as stated in the stage two complaint response. Providing incorrect information in that complaint response and then not correcting that when the error was pointed out is fault.
69. As I set out in this statement, there has been significant fault in how the Council handled Mr B's case. While I could not say Mr B missed out on suitable accommodation between April 2022 and September 2022 I consider he has suffered a significant injustice as he has some uncertainty about whether his situation could have been improved if the Council had handled the case properly. Mr B also lost out on his right of appeal, experienced some uncertainty about what the Council would do to help him, faced the distress of being evicted by bailiffs and incurring additional costs and had to stay in unsuitable accommodation for longer than he should have. In addition to the £250 I refer to in paragraph 63 to reflect the period living in shared accommodation which was unsuitable for his needs I also recommended the Council apologise to Mr B. To reflect Mr B's distress and uncertainty I recommended the Council pay him an additional £750. In recommending that amount I took into account the fact Mr B's representative worked with Mr B's landlord so he does not have to pay the rent arrears he built up and that the court costs have also been covered. I further recommended the Council apologise to Mr B's representative for its failure to respond to some of his emails. The Council has agreed to my recommendations.
70. I also recommended the Council takes the following action to address the procedural issues that have arisen in this case:
• provide training to officers dealing with homeless applications on what the code of guidance and law says in relation to assessing homeless applications, how to assess whether it is reasonable for an applicant to remain living in their accommodation, when a prevention duty is owed, when a relief duty is owed, when interim accommodation should be considered and when any prevention duty, relief duty and PHP should be reviewed. That should also include a reminder of the need to issue decisions with appeal rights in writing and to ensure PHP’s are completed;
• review the procurement policy to reduce the use of shared accommodation and increase the supply of other types of temporary accommodation.
• ensure officers always carry out a suitability assessment to identify the household's needs before making a placement in shared or other temporary accommodation.
71. The Council has agreed to my recommendations.

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Agreed action

72. Within one month of my decision the Council should:
• send an apology to Mr B;
• send an apology to the representative from the citizens advice bureau that represented Mr B in his dealings with the Council; and
• pay Mr B £1,000.
73. Within two months of my decision the Council should:
• provide the Ombudsman with evidence it has arranged training for officers dealing with homeless applications in relation to the requirements set out in the first bullet point of paragraph 70 of this statement;
• review the procurement policy to identify ways to expand the type of accommodation available to the Council to house homeless applicants to ensure there is sufficient self-contained accommodation available for applicants for whom shared accommodation is unsuitable;
• remind officers of the need to carry out a suitability assessment before placing a homeless applicant in shared or other temporary accommodation.

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Final decision

74. I have completed my investigation and uphold the complaint.

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Investigator's decision on behalf of the Ombudsman