A Jankauskas v Secretary of State for Work and Pensions

Facts

The appellant, Mr A Jankauskas, claimed Personal Independence Payment on 28 June 2023. He submitted a PIP2 questionnaire dated 21 July 2023 and underwent a telephone assessment on 25 September 2023. On 29 October 2023 the Secretary of State's decision maker awarded him no points for either the daily living or the mobility component, so that no award of Personal Independence Payment was made, and a decision letter was issued. The appellant sought a mandatory reconsideration, on which the decision maker left the decision unchanged, and he appealed on 16 December 2023. The First-tier Tribunal (Social Entitlement Chamber), sitting at East London, heard the appeal on 17 December 2024 and awarded 6 points under daily living descriptors 4d and 6e — still short of the threshold for any rate of either component from 28 June 2023. The appellant's case centred on descriptor 4f, needing assistance to wash the body between the shoulder and the waist, which would have taken him to the threshold. He suffers from osteoarthritis in both shoulders, with pain, stiffness and restricted movement. The First-tier Tribunal refused permission to appeal; the Upper Tribunal granted permission on 21 October 2025. The Secretary of State supported the appeal.