Info Gov

The First-tier Tribunal (General Regulatory Chamber) has upheld the Information Commissioner's reliance on section 14(1) of the Freedom of Information Act 2000 to refuse a request about a parish council's data protection registration, finding that the request formed part of a campaign of harassment against the council even though the appellant claimed the requesting history relied on belonged not to him but to his son, who lives at the same address and shares his name.

The tribunal of Judge Hughes, Marion Palmer-Dunk and Emma Yates, deciding the appeal after a hearing on 15 June 2026, held that it did not need to resolve whether one or two individuals were behind the correspondence, because a request can be vexatious under section 14(1) where a requester acts in concert with another person, and the evidence demonstrated a clear pattern of linkage between the two requesters directed at a small parish council which had attracted no comparable interest from anyone else.

In February 2024 a request was made to the ICO, in its capacity as a public authority, for details of Irby upon Humber Parish Council's registration as a data controller over the previous five years. The ICO refused the request under section 14(1) and maintained that position in its decision notice, relying on a history of some 15 information requests recorded on its casework system between 2019 and 2022 concerning the parish council, together with associated complaints. The council had been dissolved in around 2022, and the ICO noted that the requests resumed as soon as it was reconstituted in 2024, characterising the February 2024 request as an attempt to resume a campaign of disruption.

The appellant, Colin Webb, born in 1948, appealed on the basis that he had made no previous requests to the ICO and that the regulator had wrongly attributed to him the correspondence of his son, Colin Andrew Alan Webb, born in 1971, who lives at the same address. He accused the ICO of incorrectly merging the personal data of two different people. His son provided a witness statement confirming that he had not made the February 2024 request. Neither the appellant nor his son attended the hearing to give oral evidence, and the tribunal declined the Commissioner's request for a direction that both men provide photographic identification and proof of address.

Section 14(1) of FOIA provides that a public authority is not obliged to comply with a request for information if the request is vexatious. The leading authority, Information Commissioner v Devon County Council and Dransfield, requires consideration of the burden imposed on the public authority, the motive of the requester, the value or serious purpose of the request and any harassment or distress caused, with the underlying question being whether the request represents a manifestly unjustified, inappropriate or improper use of the Act.

The evidence before the tribunal included pairs of near-identical emails and subject access requests sent to Humberside Police and to the ICO within minutes of each other from two similar email addresses at different providers, each beginning with the same "caa" prefix. The tribunal found that whether the correspondence was the work of one individual or two, the material demonstrated coordination between the requesters, and that the February 2024 request was nearly identical to a request made in February 2021, indicating an intention to continue the harassment of the parish council and to impose a burden on it for no valid reason.

The tribunal was satisfied that the request had no serious purpose proportionate to its impact, that the history of correspondence pointed to a campaign against the council, and that the Commissioner had correctly applied section 14(1). The appeal was dismissed.

Colin Webb v Information Commissioner [2026] UKFTT 990 (GRC)

Also in this section

Sep 11, 2026

Tribunal backs NPCC cost-limit refusal of request on Chinese-made police surveillance cameras

The First-tier Tribunal has dismissed an appeal against the National Police Chiefs' Council's refusal to confirm whether it holds information on the proportion of Chinese-manufactured surveillance cameras used by UK police forces, finding that the cost of establishing whether the information existed would exceed the appropriate limit under section 12(2) of the Freedom of Information Act 2000.
Sep 01, 2026

Upper Tribunal breaks with Moss and recognises article 10 right to receive information in FOIA appeals

The Upper Tribunal has held that First-tier and Upper Tribunals are not bound by precedent to automatically reject the limited right to receive information under article 10 (“Freedom of Expression”) of the European Convention on Human Rights (ECHR) recognised by the Grand Chamber in Magyar Helsinki Bizottság v Hungary departing from the 2020 decision in Moss v Information Commissioner ( that had…
Aug 27, 2026

DfE "acting in concert" argument on repeated requests rejected as campaigner's appeals fail

The First-tier Tribunal has dismissed three appeals brought by campaigner Dr Robert Abrahart against the Department for Education, upholding two findings that his requests were vexatious under section 14(1) of the Freedom of Information Act 2000 and confirming in the third that emails withheld under sections 35 and 42 were exempt, while rejecting the department's attempt to treat requests from…

InfoGov Masthead Newsletter 800