Thomas Reed v The Information Commissioner

The Information Commissioner applied the wrong legal test by focusing on information held at the time of his investigation rather than at the time of the request. Dorset Council failed to comply with its obligations under regulation 5(1) and 5(2) by not making available all relevant information held at the time of the request.

Parties: Appellant: Thomas Reed; Respondent: The Information Commissioner
Jurisdiction: England and Wales
Judgment Date: 29 September 2025
Procedural Posture: Appeal / Final Judgment
Outcome: Appeal allowed
Legal Topics: Environmental Information Regulations, Freedom of Information, CCTV Disclosure, Public Authority Duties

Information Rights Environmental Law Environmental Information Regulations Freedom of Information CCTV Disclosure Public Authority Duties

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Parties

Thomas Reed

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

1 Whether Dorset Council complied with regulation 5(1) and 5(2) of the Environmental Information Regulations 2024
2 Whether the Information Commissioner applied the correct legal test regarding the timing of information held
3 Whether the Council failed to disclose all relevant information held at the time of the request

Ratio Decidendi

Court Disposition

Appeal allowed

Orders

Substituted Decision Notice issued: Dorset Council has not complied with regulation 5(1) and 5(2) of the Environmental Information Regulations 2024.
No steps required as relevant information no longer exists.