[2025] UKUT 153 (AAC)

In paragraph 1 of the Schedule to the PIP regulations “bathe includes get into or out of an unadapted bath or shower”. The word “includes” indicates that the ordinary meaning of “bathe”, immersion in water, is being extended, and it is accepted law that this aspect of the activity is looking at the mechanical process of accomplishing that: SP v Secretary of State for Work and Pensions [2016] UKUT 190 (AAC); [2016] AACR 43. Washing is not defined.

“Assistance” means “physical intervention by another person and does not include speech”; “prompting” means reminding or encouraging or explaining by another person; “supervision” means the continuous presence of another person for the purpose of ensuring the claimant’s safety.