Mark Armstrong v The Information Commissioner

Facts

Mark Armstrong, the appellant, made a request on 27 February 2025 to the Chief Constable of Durham Constabulary ("Durham Police") for all recorded information it held on the guidance it would follow in a major investigation into historical child abuse allegations, and on staff training and vetting before staff could work on such investigations. The background was the Medomsley Detention Centre abuse, the Prisons and Probation Ombudsman's report on it, and Durham Police's Operation Seabrook. Durham Police sought clarification, which the appellant gave on 4 March 2025, and the clarification widened the request further. On 23 April 2025 Durham Police disclosed some information, gave a link to College of Policing material and withheld other information under section 31 of the Freedom of Information Act 2000, section 43 of the Freedom of Information Act 2000 and section 21 of the Freedom of Information Act 2000. On internal review it relied instead on section 14(1) of the Freedom of Information Act 2000, treating the request as vexatious. The Information Commissioner upheld that position in a decision notice dated 4 March 2026. The appellant appealed to the First-tier Tribunal under section 57 of the Freedom of Information Act 2000 on 6 March 2026. With the parties' consent, the appeal was decided without a hearing, and the Tribunal also considered closed material.