The short answer to you question is 'it could be' ... the longer answer follows....
'Reasonableness' is at the heart of CH/5216 and landlord appeal rights, and that reasonableness is also at the heart of JR proceedings...
You have said how the LA has sought to trace the claimant and from what I can see they have been very reasonable in their actions. I am therefore having difficulty in interpreting what you are saying...
Your post seems to agree that the LA has been reasonable in tracing the claimant (your tenant), but you think that the recovery from you is not reasonable? As the payee, the law says you are a target for recovery, unless the LA is not acting 'reasonably' (it's a bit more complicated than that, but this is a very shorthand way to look at CH/5216).
If you accept that the LA has done all it can, then I am afraid you are faced with the re-payment of the O/P. If you do not accept the LA has done all it can, you can challenge:
1. The steps that the LA has taken to trace your tenant through DCI etc (my guess is that they won't have done that on RATs let alone DCI), and whether they have asked her about the delay in informing of change in circs or 'misrepresenting' her situation to the LA DWP etc.
2. Depending on the above, you can challenge the target for recovery, (it would be fairer to target the person who caused the O/P, your tenant, as per HB reg 101 (2) (a) which specifically allows LA's the discretion to recovery from any person "who misrepresented or failed to disclose", if the LA has not considered that, the target for recovery is appealable as per "Wednesbury" reasonableness, (and fettering of discretion), both of which are grounds for JR.
3. In deciding the amount of recoverable O/P the LA must have tried to calculate U/E (bearing in mind that U/E is not discretionary), (again making the issue at point 1 above so much stronger that the LA will have to prove it's actions are not just reasonable, but can be evidenced as reasonable (screen printouts from DCI, and the IS/JSA systems etc).
It matters not a jot the reason for the O/P (whether IS ended, or your tenant died, or went abroad after winning the lottery). The LA must address (in a 'statement of reasons' if it likes), whether and if so how they have addressed the three points above. However, I think that if your only argument is that recovery from you is not fair, because you were not aware that an O/P was occurring, and the LA has otherwise been completely reasonable in all respects and all it's actions, any appeal you might make is in my humble opinion, likely to fail... sorry...
The problem I think that you and perhaps many RSL's are having is that CH/5216 is a complicated decision, and to fully comprehend it, you have to be completely aware of JR and what/when/how JR grounds can be brought and succeed this is not just a problem for you, but every person who for one reason or another, did something so terrible in a former life, that they now have an involvement with HB personally or professionally, (if only I paid more attention at woodwork)...
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