Peter Cleasby v University of Exeter & Anor

Peter Cleasby v University of Exeter & Anor

The University of Exeter was in contempt of court for deliberately failing to comply with a First-tier Tribunal order to disclose information within the required time. The contempt was serious due to its duration, the University's resources, and the impact on the applicant's rights. Mitigating factors included later compliance, admission, apology, and remedial steps. However, these did not outweigh the need for a financial penalty and publication to uphold the authority of the Tribunal and deter future breaches.

Parties
Applicant: Peter Cleasby; First Respondent: University of Exeter; Second Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
08 May 2026
Procedural Posture
Certification Reference for Contempt of Court Under Freedom of Information Act 2000 / Upper Tribunal Determination Following First Tier Tribunal Certification
Outcome
Contempt of court found; sanction imposed
Legal Topics
Contempt of Court, Freedom of Information, Sanctions for Non Compliance, Tribunal Orders
Administrative Law Information Law Tribunal Procedure Contempt of Court Freedom of Information Sanctions for Non Compliance Tribunal Orders

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Parties

Peter Cleasby

Applicant

University of Exeter

First Respondent

Information Commissioner

Second Respondent

Procedural Posture

Certification Reference for Contempt of Court Under Freedom of Information Act 2000 / Upper Tribunal Determination Following First Tier Tribunal Certification

Legal Issues

  1. 1 Whether the University of Exeter was in contempt of court for failing to comply with a First-tier Tribunal order to disclose information
  2. 2 What is the appropriate sanction for contempt of court by a public authority in the context of the Freedom of Information Act

Ratio Decidendi

The University of Exeter was in contempt of court for deliberately failing to comply with a First-tier Tribunal order to disclose information within the required time. The contempt was serious due to its duration, the University's resources, and the impact on the applicant's rights. Mitigating factors included later compliance, admission, apology, and remedial steps. However, these did not outweigh the need for a financial penalty and publication to uphold the authority of the Tribunal and deter future breaches.

Court Disposition

Contempt of court found; sanction imposed

Orders

  • The University of Exeter must pay a fine of £15,000 within 28 days of the decision.
  • This decision and finding of contempt will be published.