Steve Sanders v The Information Commissioner & Anor

Steve Sanders v The Information Commissioner & Anor

The Tribunal found that the request for all dismissal decisions was manifestly excessive and unreasonable, constituting a vexatious request under section 14 FOIA. While personal information exemption under section 40(2) applied to pre-September 2019 decisions, and the administration of justice exemption under section 31(1)(c) was not engaged, the volume and nature of the request rendered it vexatious. The Financial Ombudsman Service was not required to comply with the request.

Parties
Appellant: Steve Sanders; First Respondent: The Information Commissioner; Second Respondent: Financial Ombudsman Service
Jurisdiction
England and Wales
Judgment Date
21 January 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Personal Data, Vexatious Requests, Administration of Justice
Information Rights Administrative Law Freedom of Information Personal Data Vexatious Requests Administration of Justice

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Parties

Steve Sanders

Appellant

The Information Commissioner

First Respondent

Financial Ombudsman Service

Second Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the requested information is exempt under section 31(1)(c) FOIA (administration of justice)
  2. 2 Whether the requested information is exempt under section 40(2) FOIA (personal information)
  3. 3 Whether the request is vexatious under section 14 FOIA

Ratio Decidendi

The Tribunal found that the request for all dismissal decisions was manifestly excessive and unreasonable, constituting a vexatious request under section 14 FOIA. While personal information exemption under section 40(2) applied to pre-September 2019 decisions, and the administration of justice exemption under section 31(1)(c) was not engaged, the volume and nature of the request rendered it vexatious. The Financial Ombudsman Service was not required to comply with the request.

Court Disposition

Appeal dismissed

Orders

  • The Financial Ombudsman Service is not required to disclose the information requested by the Appellant on 22 January 2022, due to the request being considered vexatious pursuant to section 14 of the Freedom of Information Act 2000.