It is settled law that walking is a "bodily function" and I don't see why using stairs is not an extension of that function. The need for assistance with any form of mobilisation can be taken into account in arriving at their care needs. Your client might visit family or friends, hospitals, and GP surgeries, etc, where help with stairs would be needed and may be artificially restricting his activities to avoid them.
On the other hand, it does make sense for people who can't do stairs to live somewhere where that isn't a problem, But don't neglect those steps outside the front door, as he is never required to be a prisoner in his own home.
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