Hakki v Secretary of State for Work and Pensions

Minor – Maintenance. The Upper Tribunal (Administrative Appeals Chamber) found that the claimant professional gambler was obliged to pay child support maintenance on the First-tier Tribunal's (Social Security) factual findings that he was 'gainfully employed' as a 'self-employed earner'. The claimant appealed. The Court of Appeal, Civil Division, in allowing the appeal, held that, on the facts, it could not be said that the claimant had had a sufficient organisation in his poker playing to make it amount to a trade or a business. However, it noted the Secretary of State's comment that there might be a way to compel him to make such contribution by making a 'departure direction'.