[Name and address of local authority]

By first class post & email to: [email address]

[Date]

Dear 
Our client: [Name and address of client]
Request for temporary accommodation pending review of homeless decision 
Housing (Wales) Act 2014, section 69(11)
We write on behalf of the above named, to ask that the Council secure interim accommodation pending the outcome of the review you are undertaking of the homelessness decision dated [date].  We enclose signed authority for us to act in this matter.
Our reasons for requesting accommodation pending review are given below.  In view of the matters outlined below and the principles set out in R v Camden LBC ex p Mohammed (1998) 30 HLR 315, QBD, we submit that our client should be accommodated.
[Detail facts of case and argument addressing:
* Flaws in decision and flaws in how the was made and strength of the applicant’s case that the original decision was wrong
* New material and information
* The applicant’s and household members’ personal circumstances and the likely adverse consequences for them if accommodation is not secured
* Likely risks to any children
* Any disabilities
* Other relevant considerations]

Deadline for response
Please reply to us in writing by [time] on [date] so we may advise our client on applying for leave for judicial review.  If you refuse to secure interim accommodation pending review please set out your reasons for that refusal in full.

Request for disclosure of homelessness and housing file records
Please forward a complete copy of our client’s housing files, including any electronic records.  
We ask that the records be forwarded as soon as possible. We reserve the right to make further representations in support of this request following receipt of those records.  

We look forward to hearing from you shortly.

Yours sincerely




[Name]
[Job title]

Enc: signed authority


W_HLESS_S85_REVIEW_05
From advisor to local authority
Request for interim temporary accommodation pending the outcome of a s.85 homelessness review