E Williams v The Information Commissioner

E Williams v The Information Commissioner

The First-tier Tribunal gave adequate and intelligible reasons for finding Mr Williams' request vexatious, considering the context of multiple previous similar requests and the lack of public value in disclosure during an ongoing investigation. The absence of a prior Tribunal balancing decision on public interest did not require further explanation. There was no error of law.

Parties
Appellant: Mr E Williams; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
27 February 2023
Procedural Posture
Appeal / Upper Tribunal Decision on Appeal From First Tier Tribunal
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Vexatious Requests, Public Interest Test, Tribunal Procedure
Administrative Law Information Law Freedom of Information Vexatious Requests Public Interest Test Tribunal Procedure

Case Brief

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Parties

Mr E Williams

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Upper Tribunal Decision on Appeal From First Tier Tribunal

Legal Issues

  1. 1 Whether the First-tier Tribunal erred in law by failing to explain why a request with a serious and genuine underlying purpose was vexatious in the absence of any earlier Tribunal determination balancing public interests for and against disclosure of similar information held by the IOPC.

Ratio Decidendi

The First-tier Tribunal gave adequate and intelligible reasons for finding Mr Williams' request vexatious, considering the context of multiple previous similar requests and the lack of public value in disclosure during an ongoing investigation. The absence of a prior Tribunal balancing decision on public interest did not require further explanation. There was no error of law.

Court Disposition

Appeal dismissed

Orders

  • The decision of the First-tier Tribunal is upheld; the appeal is dismissed under section 11 of the Tribunals, Courts and Enforcement Act 2007.