Stephanie Brown v The Information Commissioner

Stephanie Brown v The Information Commissioner

Request 1 was not vexatious under s14(1) FOIA. The request was precise, concise, and not burdensome; it had value and a serious purpose in public accountability; there was no evidence of improper motive or likelihood of harassment or distress to staff. The Trust was not entitled to refuse the request as vexatious, and the Decision Notice was not correct in law.

Parties
Appellant: Stephanie Brown; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
20 May 2025
Procedural Posture
Appeal / First Tier Tribunal (general Regulatory Chamber) Decision on the Papers
Outcome
Appeal allowed
Legal Topics
Freedom of Information, Vexatious Requests, Public Accountability, Data Protection
Information Law Administrative Law Freedom of Information Vexatious Requests Public Accountability Data Protection

Case Brief

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Parties

Stephanie Brown

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / First Tier Tribunal (general Regulatory Chamber) Decision on the Papers

Legal Issues

  1. 1 Whether the Trust was entitled to refuse Request 1 as vexatious under s14(1) FOIA
  2. 2 Whether the Decision Notice by the Information Commissioner was correct in law

Ratio Decidendi

Request 1 was not vexatious under s14(1) FOIA. The request was precise, concise, and not burdensome; it had value and a serious purpose in public accountability; there was no evidence of improper motive or likelihood of harassment or distress to staff. The Trust was not entitled to refuse the request as vexatious, and the Decision Notice was not correct in law.

Court Disposition

Appeal allowed

Orders

  • The Decision Notice is set aside.
  • The Trust must answer Request 1 in accordance with FOIA, without relying on s14(1) FOIA.