I'm not sure your reading of the reg is correct. Reg 6(8) provides for the date of claim for the purposes of DLA/AA where a claim form is requested and returned within the time specified. I cannot see anything there which allows the SoS to determine "such longer period as the SoS may consider reasonable".
There is such a power in reg 4(7) where a claim, or a document that might be treated as claim is received at the office but does not meet the requirements of a valid claim in reg 4(1). I would expect decisions of this type to appear in the list of schedule 2 to the D&A regs, but it doesn't.
S.76 SSCBA is quite clear that no entitlement to DLA can arise for a period before the date of claim (with specific exceptions), and since the claim was returned outside of the time specified provided for by reg 8 D&A regs and there is no discretion to extend that period, then, regardless of the reason, the date of claim cannot be before the completed form was received by the BDC.
That said, I've just gone on to read the definition of " the time specified" in reg 6(9), which says that the time specified is six weeks or such longer period as the SoS may consider reasonable. That does indeed suggest that disrection is conferred. Playing Devil's advocate, I might suggest that given the tense of the regulation as a whole, the discretion must be exercised at the point the form is issued, rather than after the form has been returned beyond the time already specified. So for example, a person who wants to claim, whose hands are in plaster for eight weeks and who has no-one else to help, might be given a 'time specified' of ten weeks.
An interesting question; I'm surprised it hasn't attracted much interest.
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