Peter Stead v The Information Commissioner

Peter Stead v The Information Commissioner

The request was not vexatious under section 14(1) FOIA as it did not impose a significant burden, was not motivated by improper purpose, had reasonable foundation and value, and there was insufficient evidence of harassment or distress. The University was not entitled to rely on section 14(1) FOIA to refuse the request.

Parties
Appellant: Peter Stead; Respondent: The Information Commissioner; Interested Party: Governing Body of the University of York
Jurisdiction
England and Wales
Judgment Date
03 July 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal allowed
Legal Topics
Freedom of Information, Vexatious Requests, Public Interest, Disclosure of Official Documents
Information Rights Administrative Law Freedom of Information Vexatious Requests Public Interest Disclosure of Official Documents

Case Brief

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Parties

Peter Stead

Appellant

The Information Commissioner

Respondent

Governing Body of the University of York

Interested Party

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the University was entitled to rely on section 14(1) FOIA to refuse the information request
  2. 2 Whether the request was vexatious under section 14(1) FOIA

Ratio Decidendi

The request was not vexatious under section 14(1) FOIA as it did not impose a significant burden, was not motivated by improper purpose, had reasonable foundation and value, and there was insufficient evidence of harassment or distress. The University was not entitled to rely on section 14(1) FOIA to refuse the request.

Court Disposition

Appeal allowed

Orders

  • The University must issue a fresh response to the request within 35 calendar days, confirming whether it holds the information and either supply the information sought or serve a refusal notice under section 17 FOIA relying on grounds other than section 14(1).
  • Failure to comply may amount to contempt and may be certified to the Upper Tribunal.