Paul Gerard Leaney v Information Commissioner

Paul Gerard Leaney v Information Commissioner

The Tribunal has no jurisdiction to consider the merits or substantive outcome of the complaint under section 166 DPA 2018, and the Information Commissioner provided an outcome to the Second Complaint. No further procedural steps were required, and the remedy sought by the applicant is outside the Tribunal's powers.

Parties
Appellant: Paul Gerard Leaney; Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
19 September 2025
Procedural Posture
Information Rights Appeal / Strike Out Application, Final Decision
Outcome
application struck out for want of jurisdiction and no reasonable prospect of success
Legal Topics
Data Protection Act 2018 Section 166, Subject Access Request, Jurisdiction of Tribunal, Procedural Requirements, Scope of Tribunal Powers
Data Protection Information Rights Administrative Law Data Protection Act 2018 Section 166 Subject Access Request Jurisdiction of Tribunal Procedural Requirements Scope of Tribunal Powers

Case Brief

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Parties

Paul Gerard Leaney

Appellant

Information Commissioner

Respondent

Procedural Posture

Information Rights Appeal / Strike Out Application, Final Decision

Legal Issues

  1. 1 Whether the Tribunal has jurisdiction to consider the application under section 166 of the Data Protection Act 2018
  2. 2 Whether the Information Commissioner failed to take appropriate procedural steps in responding to the complaint
  3. 3 Whether the Tribunal can order the Information Commissioner to review prior cases or the substantive outcome of a complaint

Ratio Decidendi

The Tribunal has no jurisdiction to consider the merits or substantive outcome of the complaint under section 166 DPA 2018, and the Information Commissioner provided an outcome to the Second Complaint. No further procedural steps were required, and the remedy sought by the applicant is outside the Tribunal's powers.

Court Disposition

application struck out for want of jurisdiction and no reasonable prospect of success

Orders

  • The application is struck out under Rule 8(2)(a) because the Tribunal does not have jurisdiction to deal with it.
  • The application is struck out under Rule 8(3)(a) because there is no reasonable prospect of it succeeding.