Aram Panossian v Information Commissioner

Aram Panossian v Information Commissioner

The Tribunal's jurisdiction under section 166 DPA is strictly limited to procedural failings. Since the Commissioner provided an outcome to the Applicant's complaint, the Tribunal cannot consider the merits or adequacy of that outcome. The Applicant's arguments fall outside the Tribunal's powers, and there is no reasonable prospect of the case succeeding.

Parties
Applicant: Aram Panossian; Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
06 May 2025
Procedural Posture
Information Rights Appeal / Strike Out Application; Reconsideration After Procedural Irregularity
Outcome
Application struck out
Legal Topics
Section 166 Data Protection Act 2018, Tribunal Jurisdiction, Procedural Irregularity, Subject Access Requests, Personal Data Definition
Data Protection Information Rights Administrative Law Section 166 Data Protection Act 2018 Tribunal Jurisdiction Procedural Irregularity Subject Access Requests Personal Data Definition

Case Brief

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Parties

Aram Panossian

Applicant

Information Commissioner

Respondent

Procedural Posture

Information Rights Appeal / Strike Out Application; Reconsideration After Procedural Irregularity

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction under section 166 DPA to consider the applicant's complaints about the handling of his subject access request
  2. 2 Whether the Commissioner failed to take appropriate procedural steps to respond to the complaint
  3. 3 Whether the Tribunal can consider the merits of the complaint or only procedural aspects

Ratio Decidendi

The Tribunal's jurisdiction under section 166 DPA is strictly limited to procedural failings. Since the Commissioner provided an outcome to the Applicant's complaint, the Tribunal cannot consider the merits or adequacy of that outcome. The Applicant's arguments fall outside the Tribunal's powers, and there is no reasonable prospect of the case succeeding.

Court Disposition

Application struck out

Orders

  • The decision of 7 March 2025 striking out the application is set aside due to procedural irregularity under Rule 41(2)(d).
  • The proceedings are struck out under Rule 8(3)(c) as there is no reasonable prospect of success.