Steele v Information Commissioner & Anor [2025] UKFTT 1203 (GRC) (10 October 2025)

Steele v Information Commissioner & Anor [2025] UKFTT 1203 (GRC) (10 October 2025)

On the balance of probabilities, Transport for London does not hold the information requested by the Appellant because the technology described (fusion of Radar, Lidar, and vision sensors in ULEZ cameras) is not used by TfL. Therefore, TfL was entitled to refuse the request under Regulation 12(4)(a) EIR, as no duty of disclosure arises for information not held.

Citation
[2025] UKFTT 1203 (GRC)
Parties
Appellant: Mark Steele; First Respondent: The Information Commissioner; Second Respondent: Transport for London
Jurisdiction
United Kingdom
Judgment Date
10 October 2025
Procedural Posture
Appeal Under Environmental Information Regulations 2004 (eir) / First Tier Tribunal (general Regulatory Chamber) Final Decision
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations 2004, Freedom of Information Act 2000, Public Authority Duties, Disclosure of Environmental Information, Exceptions to Disclosure
Information Rights Environmental Law Administrative Law Environmental Information Regulations 2004 Freedom of Information Act 2000 Public Authority Duties Disclosure of Environmental Information Exceptions to Disclosure

Case Brief

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Parties

Mark Steele

Appellant

The Information Commissioner

First Respondent

Transport for London

Second Respondent

Procedural Posture

Appeal Under Environmental Information Regulations 2004 (eir) / First Tier Tribunal (general Regulatory Chamber) Final Decision

Legal Issues

  1. 1 Whether Transport for London holds information responsive to the Appellant's requests under the Environmental Information Regulations 2004 regarding ULEZ camera technology and environmental risk.
  2. 2 Whether the refusal to disclose information was lawful under Regulation 12(4)(a) EIR.

Ratio Decidendi

On the balance of probabilities, Transport for London does not hold the information requested by the Appellant because the technology described (fusion of Radar, Lidar, and vision sensors in ULEZ cameras) is not used by TfL. Therefore, TfL was entitled to refuse the request under Regulation 12(4)(a) EIR, as no duty of disclosure arises for information not held.

Court Disposition

Appeal dismissed