Peter Tilson v The Information Commissioner & Anor

Peter Tilson v The Information Commissioner & Anor

The Tribunal found that the Appellant's request was manifestly unreasonable due to the disproportionate burden it would place on the Council, the minimal objective public interest in the information sought, and the context of repeated requests arising from a personal grievance. The public interest in disclosure was significantly outweighed by the burden on the authority, and the Council was not required to provide further advice and assistance. The Information Commissioner's decision notice was in accordance with the law.

Parties
Appellant: Peter Tilson; 1st Respondent: The Information Commissioner; 2nd Respondent: Northumberland County Council
Jurisdiction
England and Wales
Judgment Date
22 September 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Manifestly Unreasonable Requests, Public Interest Test, Advice and Assistance Duty, Planning Law, Vexatious Requests
Administrative Law Environmental Law Freedom of Information Environmental Information Regulations Manifestly Unreasonable Requests Public Interest Test Advice and Assistance Duty Planning Law +1 more

Case Brief

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Parties

Peter Tilson

Appellant

The Information Commissioner

1st Respondent

Northumberland County Council

2nd Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the Council was entitled to refuse the Appellant's request under Regulation 12(4)(b) of the Environmental Information Regulations 2004 as manifestly unreasonable
  2. 2 Whether the Council complied with its duty to provide advice and assistance under Regulation 9 EIR
  3. 3 Whether the public interest balance test under Regulation 12(1)(b) EIR was correctly applied

Ratio Decidendi

The Tribunal found that the Appellant's request was manifestly unreasonable due to the disproportionate burden it would place on the Council, the minimal objective public interest in the information sought, and the context of repeated requests arising from a personal grievance. The public interest in disclosure was significantly outweighed by the burden on the authority, and the Council was not required to provide further advice and assistance. The Information Commissioner's decision notice was in accordance with the law.

Court Disposition

Appeal dismissed

Orders

  • The appeal is dismissed.
  • The Decision Notice of the Information Commissioner dated 12 November 2024 is upheld.