Benefit overpayment and deduction from benefits

Does anyone know whether the DWP can deduct money from a new claim for benefits to recover a benefit overpayment which is over 12 years old. I am aware of a case - Joseph vs Newham borough council 2009 where it was decided that the DWP was not allowed to recover debts that are over 6 years old from benefits. Has there been a more recent decision overturning this?

In the case of my client, he believes the debt was cleared as part of an Admin Order many years ago but of course he cannot prove this because neither himself or the court has any records.

Thanks

On the implications of the Joseph decision see:

http://www.rightsnet.org.uk/forums/viewthread/2772/

I can’t see the Joseph decision stopping the DWP for section 71 recovery at this moment in time without the courts interfering again.