MB v Secretary of State for Work and Pensions & Anor (CSM)

The First-tier Tribunal erred in law by failing to make sufficient findings of fact regarding whether the home insurance payments qualified as special expenses under Regulation 65(3)(i). The decision is set aside and remitted for reconsideration by a fresh tribunal.

Parties: Appellant: MB; First Respondent: Secretary of State for Work and Pensions; Second Respondent: JB
Jurisdiction: England and Wales
Judgment Date: 09 September 2025
Procedural Posture: Appeal / Upper Tribunal Decision on Appeal From First Tier Tribunal
Outcome: Appeal allowed; First-tier Tribunal decision set aside and case remitted for reconsideration.
Legal Topics: Child Maintenance, Special Expenses Variation, Tribunals Procedure

Family Law Social Security Law Child Maintenance Special Expenses Variation Tribunals Procedure

Case Brief

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Parties

Appellant

Secretary of State for Work and Pensions

First Respondent

Second Respondent

Procedural Posture

Appeal / Upper Tribunal Decision on Appeal From First Tier Tribunal

Legal Issues

1 Whether home insurance payments of £25 per month paid by the Second Respondent to the Appellant are deductible as special expenses under Regulation 65 of the Child Support Maintenance Calculation Regulations 2012

Ratio Decidendi

Court Disposition

Appeal allowed; First-tier Tribunal decision set aside and case remitted for reconsideration.

Orders

Case remitted to the First-tier Tribunal for reconsideration.
Parties to submit further relevant evidence regarding the nature or purpose of the home insurance policy.