There has been some discussion about the legal basis for coronavirus visa extensions and whether the application process gives the applicant the protection of section 3C.
These doubts were originally raised at a time when the application was via email. Now a form-based application process, of sorts, exists. It is at least arguable that completing the online form for a coronavirus extension is a valid application for leave under paragraph 34 of the Immigration Rules.
All the requirements of paragraph 34 appear to be met. The fact that the person intends to leave the UK but cannot because of COVID-19 is arguably a good reason why he is not providing proof of ID (as otherwise required by paragraph 34(5)(a)). Applicants are complying with the application process set out — paragraph 34(9) — which has not stipulated that biometrics must be enrolled.
In terms of appealing a refusal, provided the person raises human rights issues on the form arguably it is akin to an FLR(FP) or an FLR(HRO) application for leave outside the Rules. The fact that two alternative paid applications exist would not preclude this application being a human rights claim. It could thus generate raise an in-country right of appeal under section 82(1) of the Nationality, Immigration and Asylum Act 2002. It would be advisable to retain evidence of making the application by taking a screenshot of the completed form before submitting it, and of the email confirmation after submission.
As previous posts have pointed out, the legal basis for blanket extensions (such as those for NHS workers) is unclear. A cautious approach would mean a paid in-time application. But this no-fee application may present an opportunity to extend leave by virtue of section 3C.