Any benefit to PIP appeal submission?

Just hoping I could get a feel for what others think.

I am helping a client with her PIP appeal. 6 points for DL and 4 for Mob at initial claim.

I had submitted a detailed online MR claim identifying which descriptors applied and why. The DWP MR response literally just copied and pasted the criteria for each activity but nothing that related specifically to my client’s claim or addressed the points raised in the MR.

For appeal I just pointed out that the MR was particularly unhelpful and therefore attached the MR as the reasons for appeal saying they had not raised anything I could address.

The DWP’s submission to the Tribunal lists the evidence they used for their decision but this is just regurgitating points from the health assessment but without any additional comments. Again they haven’t addressed the points raised in the appeal/MR.

My client’s husband has written a diary of how he helps and I have asked her GP for supporting evidence (not confident this will help but worth asking anyway).

So, the point of my query is, is there any point in writing a submission for the Tribunal as I would normally do? I can’t see anything new to add and I know Tribunals can get rather irritated if they feel their time is being wasted so I don’t want to just repeat what I have already said.

Thanks in advance.

Maybe just a short submission summarising what you’ve set out in this post, to demonstrate that your client has made valiant attempts to show why they are entitled and how poor the DWP response has been? That way, you can, for example, highlight your previous MR request which contains the grounds for the appeal.

I tend to do my MRs like this. Laying out the points and the supporting evidence. When it comes to appeal (as it often does) I simply note in the SSCS1 that all salient arguments have been laid out in the MR; enclose a copy of that and march onwards. Never been an issue. If anything it helps a tad in some cases where it’s very obvious the matter, properly handled, ought never to have gone near an appeal hearing. Have had judges asked for SORs by DWP very pointedly mention that the full arguments were laid out at MR. The inference being “Nope, we have no idea why DWP think we won’t have noticed that this entire matter need never have come near us.”

The value of an ‘appeal submission’ is to be a complete statement which functions as the final word on what the appellant’s case is, taking account of the relevant evidence and making appropriate representations. In the tradition of welfing, that has been done in a special document in advance of the hearing, but there’s no procedural reason why that needs to be the case and a document submitted at an earlier stage of the process could just as well fulfil the same function.

As you have already said what you want to say, I don’t see why you should feel compelled to copy and paste what you have already written into a new document and make the same representations again just wearing a different hat. I would just write to the tribunal and say that you have read the bundle, have nothing more to add to what is stated in the MR request and your client would rely on that as setting out their position.

Thanks Paul/Mike/Elliot for your input. Glad to learn that my gut feeling isn’t too far off. I may do a very short submission just to signpost the Tribunal but won’t bother with anything detailed.