Right of permanent residence for EEA national ...

You may need to get a breakdown (if you have not done so already) from the client as to his work history from 1993 to 2010, and for what periods and how long was he not paying tax and NI?  You say there is no record of him being a qualified person.  Does this mean he was never paying tax or NI, and there are no P60s or P45s?  What evidence of work, is client able to produce, letters from employers, wage slips?

Does client have a family member, who would pass the permanent residence test, from whom he could qualify?

Thanks Domino !
I thought that would be the path to follow and yes, he has got a son in UK but he is in receipt of IBJSA ...
Have a good day !!

I have clients in this situation. Their employers did not pay taxes/NI contributions and there was no trace of their existence in HMRC’s records. However, I could track employers or witnesses and receive written evidence of the jobs (e-mails for example). This evidence was accepted by the tribunal, as corroborating the clients’ testimony. A job is ‘work’ under the EU laws even if taxes were not paid.

Make sure you can convince the tribunal that all the work was not ancillary or marginal - this is normally easy. And check the continuity of your client’s history: long gaps between jobs should be covered by claims for JSA or evidence of sickness. Smaller gaps can be accepted.

“A job is ‘work’ under the EU laws even if taxes were not paid.”  Judge Jacobs goes even further in this very useful decision.

Hmmmm ...
Lots to work on since I last looked, thank you all !
Now have breakdown of cl employment, or otherwise, history in UK since 1993 and will progress case accordingly ...
Will let you know the outcome and have a good weekend !!