Mark Bill v Information Commissioner
The request was exceptionally broad and unfocussed, imposing an undue and disproportionate burden on the NHS Trust (approximately 100 hours of work), with only limited and generalised public interest value. The appellant's repetitive and demanding pattern of prior requests further reinforced the vexatious nature. The Commissioner correctly applied s.14 FOIA; the appeal disclosed no error of law.
- Parties
- Appellant: Mark Bill; Respondent: Information Commissioner
- Jurisdiction
- England and Wales
- Judgment Date
- 17 June 2025
- Procedural Posture
- Appeal / Final Judgment
- Outcome
- appeal dismissed
- Legal Topics
- Freedom of Information Act, Vexatious Requests, Public Authority Resources, Transparency, Public Interest
Case Brief
Summary, issues, holding and outcome
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Parties
Mark Bill
Appellant
Information Commissioner
Respondent
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Whether the Information Commissioner's decision that the appellant's FOIA request was vexatious under s.14 FOIA was correct
- 2 Whether the burden imposed by the request outweighs its public interest value
Ratio Decidendi
The request was exceptionally broad and unfocussed, imposing an undue and disproportionate burden on the NHS Trust (approximately 100 hours of work), with only limited and generalised public interest value. The appellant's repetitive and demanding pattern of prior requests further reinforced the vexatious nature. The Commissioner correctly applied s.14 FOIA; the appeal disclosed no error of law.
Court Disposition
appeal dismissed
Orders
- Appeal refused
- No further action required by the NHS Trust
Full Case Text
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