In May 2014, it was reported the DWP was employing debt collectors to retrieve overpaid benefits, the overpayment purely down to calculation mistakes by HM Revenue and Customs. After the "workfare" element of the Work Programme was successfully challenged in the courts in 2013, Duncan Smith sought to re-establish the legality of the scheme through retrospective legislation but, in July 2014, the High Court ruled the retrospective nature of the legislation interfered with the "right to a fair trial" under Article 6 of the European Convention on Human Rights. The DWP had said 1 million people would be placed on the new Universal Credit benefits system by April 2014, yet by October 2014 only 15,000 were assigned to UC. Duncan Smith said a final delivery date would not be set for this, declaring "Arbitrary dates and deadlines are the enemy of secure delivery."