Joanita Nalubowa

Deputy Prime Minister and Secretary of State for 
Housing, Communities & Local Government 
2 Marsham Street  
London  
SW1P 4DF  

Our reference: 

13 December 2024  

Harry Lambert  
Assistant Coroner  
Inner North London  
Bow Coroner’s Court  
Bow Road  
London  
E3 3AA 

Dear Mr Lambert, 

RESPONSE TO REGULATION 28: REPORT TO PREVENT FUTURE DEATHS - INQUEST INTO 
THE DEATH OF JOANITA NALUBOWA 

Thank  you  for  your  letter  and  investigative  report  dated  13  August  2024  into  the  tragic  death  of 
Joanita Nalubowa, which was made in accordance with Paragraph 7, Schedule 5, of the Coroners 
and Justice Act 2009 and Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013.   

First, I want to express my sincere condolences to Ms Nalubowa’s family and friends. I was very 
sorry to read about her death, and the situation and circumstances that led to her tragically taking 
her own life. It is vitally important that vulnerable individuals are provided with the support and care 
they  deserve.  As  a  victim  of  domestic  abuse  experiencing  mental  health  challenges,  from  the 
evidence provided and the information in your report, it appears that at a crucial time, Ms Nalubowa’s 
needs were not met and that the system failed and let her down.  

I have provided more detail below on the relevant frameworks that should have been in place  to 
support  Ms  Nalubowa  to  access  homelessness  support  or  social  housing.  From  the  evidence 
provided, it appears that these frameworks failed Ms Nalubowa in practice. I will be writing to the 
local  authorities  concerned  to  remind  them  of  their  statutory  duties  in  this  regard.  I  will 
reiterate  my  expectation  that  local  authorities  should  place  a  high  level  of  importance  on 
using  the  discretion  available  to  them  when  assessing  applications  for  homelessness 
support or social housing, particularly for vulnerable people such as Ms Nalubowa.  

In  addition,  the  Government  will  bring  forward  changes  to  social  housing  allocations 
regulations to apply exemptions to victims of domestic abuse from local authority residency 
and local connection tests. This will ensure all local authorities must provide this exemption. 

Below I set out more on the specific aspects and explain in more detail the steps I am proposing to 
take to ensure that the tragic situation that Ms Nalubowa faced is not experienced by others.  

  
 
 
  
     
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 Matter of Concern 1: Aftercare support where section 117 Mental Health Act 1983 does not 
apply   

My Department is committed to continuing to work with the Department of Health and Social Care 
(DHSC)  to  ensure  the  effective  interaction  between  health  and  housing  support  services.  On  6 
November, DHSC introduced a Mental Health Bill to reform the existing Mental Health Act and make 
it fit for the 21st Century, improving patients’ experiences of hospital and mental health outcomes 

(Better care for mental health patients under major reforms - GOV.UK). The Bill will improve decision 
making around detention, discharge, care and treatment. Discharge processes will also be reviewed 
more broadly and will include a safety management plan for the patient, to keep themselves and 
others safe. 

Matter of Concern 2: Housing Support  

My  Department  is  responsible  for  the  statutory  frameworks  that  govern  both  homelessness  and 
access to social housing. The Housing Act 1996 Part 7 sets out the duties local housing authorities 
have  towards  homeless  households,  and  the  Housing  Act  1996  Part  6  sets  out  social  housing 
provision.  

Based on the evidence provided, there are several aspects of these legislative frameworks that may 
have been of relevance to Ms Nalubowa’s experience of seeking accommodation support.   

Homelessness – Local Connection 

As set out at S184(2) of the Housing Act 1996, when a local authority makes inquiries to determine 
whether an applicant is owed homelessness duties, part of these inquiries can be to establish if an 
applicant has an existing local connection. 

In instances where the duty has been accepted by an authority, but the applicant does not have a 
local connection with that authority, the authority may refer the applicant to a local authority where 
the  applicant  does  have  a  local  connection.  However,  the  ability  of  a  local  authority  to  refer  is  a 
power, rather than a duty, and so it is at the authority's discretion to make a referral.   

Importantly, as set out within the S198 of the Housing Act 1996, certain conditions must be met in 
order for a referral to be made, one of which is that the person would not be at risk of domestic 
abuse in the area where the referral would otherwise be made.   

In  circumstances  where  an  applicant  is  at  risk  of  domestic  abuse  in  a  certain  area,  which  as 
suggested in your report may have been a factor that led Ms Nalubowa to seek support in London 
rather  than  Stockton,  an  authority  cannot  refer  them  to  an  area  where  they  would  be  at  risk 
(S198(2)(c), and must instead accept the homelessness duty themselves.   

The statutory Homelessness Code of Guidance is also clear that local housing authorities should 
enquire  whether  the  applicant  would  be  at  such  a  risk,  and  stipulates  that  authorities  should  not 
impose a high standard of proof when making its decision (Local connection and referrals to another 
housing authority – Homelessness Code of Guidance – GOV.UK.) From the evidence provided, it 
appears that in Ms Nalubowa’s case the legislation may not have been applied as intended. 

Social Housing – Access and Priority  

 
   
 
 
 
 
  
 
 
 
 
 Local  authorities  have  the  power  to  manage  their  own  allocation  scheme  and  by  law  must  give 
certain people ‘reasonable preference’ (priority)  for  an allocation of  social housing.  This  includes 
people who are homeless, or who need to move for medical or welfare reasons (including those 
suffering from mental illness). Local authorities can also give ‘additional preference’ (high priority) 
to those in the reasonable preference categories that  have very urgent housing needs. Statutory 
guidance  is  clear  that  local  authorities  should  consider  giving  additional  preference  to  those 
escaping domestic abuse.  

Guidance is also clear that local authorities have powers to exempt victims of domestic abuse from 
any local connection tests to determine who qualifies for an allocation of social housing and should 
consider  the  needs  of  those  that  require  support  to  rehabilitate  and  integrate  back  into  the 
community.  

From  the  evidence  provided,  it  appears  that  the  frameworks  governing  social  housing  and 
homelessness failed Ms Nalubowa in practice. I will be writing to the local authorities concerned to 
remind  them  of  their  statutory  duties  in  this  regard  and  to  ensure  awareness  of  the  flexibilities 
provided. I will reiterate my expectation that local authorities should place a high level of importance 
on using the discretion available  to them when assessing applications, particularly for vulnerable 
people such as Ms Nalubowa.  

The  Prime  Minister  also  announced  on  24th  September  that  the  Government  will  bring  forward 
changes to social housing allocations regulations to apply exemptions to victims of domestic abuse 
from local authority residency and local connection tests. This will ensure that all local authorities 
must provide these exemptions.  

I also want to reiterate the Government’s commitment to working with councils, partners and other 
stakeholders to support vulnerable groups, including those who are vulnerable due to mental illness. 
Nobody  should  feel  afraid  in  their  own  home  and  we  are  committed  to  halving  violence  against 
women and girls in a decade, and we will do everything in our power to achieve this and use every 
lever  across  government.  As  part  of  this  work,  and  learning  from  Ms  Nalubowa’s  tragic 
circumstances, we are determined to explore what more can be done to reduce barriers to access 
social housing so that we can provide help for those who need it most.   

Thank you for bringing the tragic death of Ms Nalubowa to my attention and once again, I wish to 
express my sincere condolences to Ms Nalubowa’s family and friends. 

Yours sincerely,  

Deputy Prime Minister and Secretary of State for Housing, Communities & Local Government