Peter Stead v The Information Commissioner

Peter Stead v The Information Commissioner

The Tribunal found that the University was entitled to rely on section 22A FOIA to withhold the requested information because the research programme was ongoing, further publication was intended, and premature disclosure would likely prejudice the University's interests and the integrity of the research. The public interest in maintaining the exemption outweighed the public interest in disclosure, especially given the imminent conclusion of the research and planned publication. No error of law or wrongful exercise of discretion by the Commissioner was established.

Parties
Appellant: Peter Stead; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
01 September 2025
Procedural Posture
Appeal (information Rights) / Final Judgment (appeal Dismissed)
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Research Exemption, Public Interest Test, Academic Research, Disclosure of Information
Information Law Administrative Law Freedom of Information Research Exemption Public Interest Test Academic Research Disclosure of Information

Case Brief

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Parties

Peter Stead

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal (information Rights) / Final Judgment (appeal Dismissed)

Legal Issues

  1. 1 Whether section 22A FOIA (research exemption) was correctly engaged by the University of York to withhold information about the 'Safe to Speak Up?' report
  2. 2 Whether the public interest balancing test under section 22A FOIA was properly conducted by the Information Commissioner
  3. 3 Whether the Commissioner erred in law or wrongfully exercised discretion in upholding the University's refusal to disclose the requested information

Ratio Decidendi

The Tribunal found that the University was entitled to rely on section 22A FOIA to withhold the requested information because the research programme was ongoing, further publication was intended, and premature disclosure would likely prejudice the University's interests and the integrity of the research. The public interest in maintaining the exemption outweighed the public interest in disclosure, especially given the imminent conclusion of the research and planned publication. No error of law or wrongful exercise of discretion by the Commissioner was established.

Court Disposition

Appeal dismissed