That is my point. If civil penalties and overpayments are inextricably linked, you would not award a civil penalty unless there had been an overpayment. You can almost produce an incentive to put something into the category of an error attracting a civil penalty because it makes it easier to justify chasing the overpayment.
Welfare Reform Bill
Proceeding contribution from
Baroness Drake
(Labour)
in the House of Lords on Monday, 28 November 2011.
It occurred during Debate on bills
and
Committee proceeding on Welfare Reform Bill.
Type
Proceeding contribution
Reference
733 c15GC 
Session
2010-12
Chamber / Committee
House of Lords Grand Committee
Subjects
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Timestamp
2023-12-15 20:58:29 +0000
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