Is there any document that can be had from the Home office ( of course if it knows that the client is in UK; as a spouse, asylum seeker; or whatever) that DWP could then issue one? S1 of SSAct 1992 requires a nino, and s19 of the Fraud Act 1997 at para (1B)(b)states that: "the person makes an application for a national insurance number to be allocated to him which is accompanied by information or evidence enabling such a number to be so allocated." So I would imagine if there is any information (documented) to show she is who she is, things could happen, whilst an appeal is pending. Though from the your information it seems that circs is not as simple as I think it is.
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