Reg Oliver v The Information Commissioner

Reg Oliver v The Information Commissioner

The Tribunal found that the Appellant's requests, viewed in the context of a long-standing pattern of repetitive and overlapping correspondence, imposed a disproportionate and unjustified burden on the Council's resources. The incremental public value of further responses was limited, as the Council had already provided or signposted the relevant information. The requests were therefore properly refused as vexatious under section 14(1) FOIA and manifestly unreasonable under regulation 12(4)(b) EIR. The public interest in disclosure did not outweigh the burden and disruptive effect on the authority.

Parties
Appellant: Reg Oliver; First Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
14 April 2026
Procedural Posture
Appeal (information Rights) / Final Judgment on the Papers
Outcome
Appeal refused; Decision Notice upheld
Legal Topics
Freedom of Information, Environmental Information Regulations, Vexatious Requests, Manifestly Unreasonable Requests, Traffic Regulation Orders, Public Authority Duties
Administrative Law Information Law Environmental Law Freedom of Information Environmental Information Regulations Vexatious Requests Manifestly Unreasonable Requests Traffic Regulation Orders +1 more

Case Brief

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Parties

Reg Oliver

Appellant

The Information Commissioner

First Respondent

Procedural Posture

Appeal (information Rights) / Final Judgment on the Papers

Legal Issues

  1. 1 Whether Derbyshire County Council was entitled to refuse the Appellant's requests under section 14(1) FOIA and regulation 12(4)(b) EIR as vexatious/manifestly unreasonable
  2. 2 Whether the Information Commissioner’s Decision Notice upholding the refusal was correct in law
  3. 3 Whether the public interest in disclosure outweighed the burden on the authority

Ratio Decidendi

The Tribunal found that the Appellant's requests, viewed in the context of a long-standing pattern of repetitive and overlapping correspondence, imposed a disproportionate and unjustified burden on the Council's resources. The incremental public value of further responses was limited, as the Council had already provided or signposted the relevant information. The requests were therefore properly refused as vexatious under section 14(1) FOIA and manifestly unreasonable under regulation 12(4)(b) EIR. The public interest in disclosure did not outweigh the burden and disruptive effect on the authority.

Court Disposition

Appeal refused; Decision Notice upheld

Orders

  • The appeal is refused.
  • Decision Notice IC 314824 V7P6, dated 17 December 2024, is upheld.