Jonathan Bourne v The Information Commissioner & Anor

Jonathan Bourne v The Information Commissioner & Anor

The tribunal found that uncontrolled disclosure of the Title Number and UPRN Look Up dataset would be likely to prejudice the prevention and detection of crime by facilitating registered title fraud, and that the public interest in maintaining the exemption outweighed the public interest in disclosure. Section 31(1)(a) FOIA was engaged and justified withholding the information.

Parties
Appellant: Jonathan Bourne; 1st Respondent: The Information Commissioner; 2nd Respondent: HM Land Registry
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
FOIA Appeal / First Tier Tribunal (general Regulatory Chamber) Judgment
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Section 31 FOIA (prevention or Detection of Crime), Public Interest Test, Disclosure of Government Datasets
Information Law Administrative Law Freedom of Information Section 31 FOIA (prevention or Detection of Crime) Public Interest Test Disclosure of Government Datasets

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Parties

Jonathan Bourne

Appellant

The Information Commissioner

1st Respondent

HM Land Registry

2nd Respondent

Procedural Posture

FOIA Appeal / First Tier Tribunal (general Regulatory Chamber) Judgment

Legal Issues

  1. 1 Whether disclosure of the Title Number and UPRN Look Up dataset would be likely to prejudice the prevention or detection of crime under section 31(1)(a) FOIA
  2. 2 Whether the public interest in maintaining the exemption outweighs the public interest in disclosure

Ratio Decidendi

The tribunal found that uncontrolled disclosure of the Title Number and UPRN Look Up dataset would be likely to prejudice the prevention and detection of crime by facilitating registered title fraud, and that the public interest in maintaining the exemption outweighed the public interest in disclosure. Section 31(1)(a) FOIA was engaged and justified withholding the information.

Court Disposition

Appeal dismissed