Gabriel Kanter-Webber v The Information Commissioner & Anor

Gabriel Kanter-Webber v The Information Commissioner & Anor

Disclosure of the requested police misconduct hearing bundle and transcript/audio would be likely to prejudice the exercise of law enforcement functions by undermining witness candour and cooperation and interfering with ongoing or future misconduct investigations. The public interest in maintaining the exemption outweighs the public interest in disclosure, given the transparency already achieved through public hearings and published summaries.

Parties
Appellant: Gabriel Kanter-Webber; First Respondent: The Information Commissioner; Second Respondent: The Chief Constable of Greater Manchester Police
Jurisdiction
England and Wales
Judgment Date
19 May 2026
Procedural Posture
Freedom of Information Appeal / First Tier Tribunal (general Regulatory Chamber) Determination on the Papers
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Law Enforcement Exemptions, Police Misconduct, Public Interest Test, Open Justice
Information Law Administrative Law Police Law Freedom of Information Law Enforcement Exemptions Police Misconduct Public Interest Test Open Justice

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Parties

Gabriel Kanter-Webber

Appellant

The Information Commissioner

First Respondent

The Chief Constable of Greater Manchester Police

Second Respondent

Procedural Posture

Freedom of Information Appeal / First Tier Tribunal (general Regulatory Chamber) Determination on the Papers

Legal Issues

  1. 1 Whether disclosure of the police misconduct hearing bundle and transcript/audio is exempt under section 31(1)(g) FOIA due to likely prejudice to law enforcement functions
  2. 2 Whether the public interest in maintaining the exemption outweighs the public interest in disclosure
  3. 3 Whether section 32(1)(b) FOIA applies to the hearing bundle

Ratio Decidendi

Disclosure of the requested police misconduct hearing bundle and transcript/audio would be likely to prejudice the exercise of law enforcement functions by undermining witness candour and cooperation and interfering with ongoing or future misconduct investigations. The public interest in maintaining the exemption outweighs the public interest in disclosure, given the transparency already achieved through public hearings and published summaries.

Court Disposition

Appeal dismissed

Orders

  • The appeal is refused.
  • No further steps are required of the Information Commissioner or the Chief Constable of Greater Manchester Police.