Christopher Owen v Information Commissioner

Christopher Owen v Information Commissioner

None of the limbs of the Dransfield test for vexatiousness were met: the Council did not demonstrate undue burden, the applicant's motive was legitimate and rooted in transparency, the request had public value due to the Council's financial interest, and there was insufficient evidence of harassment or distress. Therefore, the Council was not entitled to rely on section 14(1) FOIA or regulation 12(4)(b) EIR to refuse the request.

Parties
Appellant: Christopher Owen; Respondent: Information Commissioner; Public Authority: Doncaster Metropolitan Borough Council
Jurisdiction
England and Wales
Judgment Date
17 November 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal allowed
Legal Topics
Freedom of Information, Environmental Information, Vexatious Requests, Manifestly Unreasonable Requests, Transparency in Planning Decisions
Administrative Law Information Law Freedom of Information Environmental Information Vexatious Requests Manifestly Unreasonable Requests Transparency in Planning Decisions

Case Brief

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Parties

Christopher Owen

Appellant

Information Commissioner

Respondent

Doncaster Metropolitan Borough Council

Public Authority

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the Council was entitled to rely on section 14(1) of FOIA to refuse the information request as vexatious
  2. 2 Whether the Council was entitled to rely on regulation 12(4)(b) of the EIR to refuse the request as manifestly unreasonable

Ratio Decidendi

None of the limbs of the Dransfield test for vexatiousness were met: the Council did not demonstrate undue burden, the applicant's motive was legitimate and rooted in transparency, the request had public value due to the Council's financial interest, and there was insufficient evidence of harassment or distress. Therefore, the Council was not entitled to rely on section 14(1) FOIA or regulation 12(4)(b) EIR to refuse the request.

Court Disposition

Appeal allowed

Orders

  • The public authority is not entitled to rely on section 14 FOIA or regulation 12(4)(b) EIR to refuse the requests.
  • The public authority must respond to the request for information within 35 days stating whether it holds the requested information and must either supply the information or claim any relevant exemptions or exceptions other than section 14(1) FOIA and regulation 12(4)(b) EIR.