Collins v Secretary of State for work and pensions

Summary

The decision, Collins v Secretary of State for Work and Pensions 2004, states that the habitual residence test cannot be used to restrict European Union national's access to income-based jobseeker's allowance unless the Government can show that a period residence of itself is necessary to show that the person is genuinely active in the labour market.

Mr Collins is a US/Irish national who had done casual work in the UK during a 10 month stay in 1980-81. In 1998 he returned to the UK to look for work and claimed JSA. He was refused on the basis he was not habitually resident. The European court found the following:

Mr Collins was not a worker for the purposes of Article 7(2) Regulation 1612/68 because there was no link between his current search for work and the work he had done in 1980-81
JSA falls within the scope of Article 48(2) of the Treaty as a benefit of a financial nature intended to facilitate access to employment in the labour market.
There is some doubt about the legality of the habitual residence test for JSA because that test places non-UK EU nationals at a disadvantage.
Following that decision the case was referred back to commissioners as CJSA/4065/1999. Commissioner Mesher interpreted the judgment as saying that the claimant must demonstrate that he has been genuinely seeking work for a period of time. The function of the habitual residence test is to establish this.

The appeal failed. Leave to appeal to the Court of Appeal has been granted.

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