{"id":933197,"date":"2026-05-21T01:08:02","date_gmt":"2026-05-20T23:08:02","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/edward-williams-v-the-attorney-generals-office\/"},"modified":"2026-05-21T01:08:02","modified_gmt":"2026-05-20T23:08:02","slug":"edward-williams-v-the-attorney-generals-office","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ar\/jurisprudences\/edward-williams-v-the-attorney-generals-office\/","title":{"rendered":"Edward Williams v The Attorney General’s Office"},"content":{"rendered":"
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NCN: [2026] UKFTT 00690 (GRC) Case Reference: FT\/EJ\/2026\/0002 First-tier Tribunal (General Regulatory Chamber) Information Rights Decided without a hearing Decision given on: 18 May 2026 Before JUDGE HARRIS Between EDWARD WILLIAMS Applicant and THE ATTORNEY GENERAL\u2019S OFFICE Respondent Decision: The Applicant\u2019s application for certification of the AGO to the Upper Tribunal for contempt is refused. REASONS Background to the application 1. This application relates to alleged breach of compliance with the Tribunal\u2019s decision issued on 16 December 2025 (the \u201cDecision\u201d) in appeal number FT\/EA\/2025\/0193. 2. The issue in the Decision was whether the Information Commissioner\u2019s (\u201cIC\u201d) decision dated 14 May 2025 was in accordance with the law. The IC had found that the Attorney General\u2019s Office (\u201cthe AGO\u201d) was entitled to rely on section 35(3) of the Freedom of Information Act (\u201cFOIA\u201d) to neither confirm nor deny (\u201cNCND\u201d) holding information within the scope of the Applicant\u2019s request. The Tribunal decided that the Decision was not in accordance with the law and allowed the appeal. 3. The Tribunal, as part of the Decision allowing the appeal, issued a Substituted Decision Notice (\u201cSDN\u201d). The relevant part read as follows: \u201c(2) Accordingly the public authority shall, no later than 28 days after the date of promulgation of this substituted Decision Notice, deliver a fresh response to the Appellant satisfying the requirements of FOIA s1(1)(a) and, if relevant information was held on the date of the original response, disclose the same or state any and every legal ground for declining to do so.\u201d 4. The AGO wrote to the Applicant, Mr Williams, on 14 January 2026 (the \u201cFresh Response\u201d). The AGO confirmed under FOIA section 1(1)(a) that it held some information within scope of the Appellant\u2019s request. It attached the information to its letter, with redactions applied under section 40 FOIA (personal information) to the names of junior staff. 5. The Fresh Response also stated that the request gave rise to exemptions to the requirement to confirm whether the AGO held information specified in the request. It said: \u201cIf it were held, the information in scope of this request would relate to Law Officer advice or a request for such advice, covered by section 35(1)(c) of the FOIA. As such, by virtue of section 35(3) of the FOIA, the AGO is not required to either confirm or deny whether it holds such information in scope. Further and in the alternative, if information were held in scope of this request it would relate to law enforcement, covered by s.31(1)(a) FOIA. As such, by virtue of 31(3) FOIA, the AGO is not required to either confirm or deny whether it holds such information in scope.\u201d 6. It went on to explain its reasoning behind the application of these two exemptions and stated that if the Applicant was dissatisfied with the handling of his request, he had the right to ask for an internal review. The application 7. The Applicant applied by way of form GRC4 dated 24 January 2026 for certification of contempt to the Upper Tribunal (\u201cUT\u201d) under section 61 of FOIA. His grounds for the application stated the following: \u201cDespite the tribunal's express finding that the AGO's prior reliance on s.35(3) NCND was unlawful, the fresh response reapplies NCND under s.35(3) to any further\/additional information that might be held, citing the Law Officers' Convention and related public interest factors. It also invokes NCND alternatively under s.31(3) FOIA (prejudice to prevention\/detection of crime, linked to police operational decisions). This re-application of the same exemption (s.35(3)) that the tribunal quashed \u2014 without evidence of materially changed circumstances or a fresh search\/disclosure exercise curing the prior defect \u2014 fails to satisfy the order's requirement for a genuine "fresh response" fully complying with s.1(1)(a) FOIA (confirmation or denial of holding). The partial disclosure of limited material does not address the core of the request; the NCND position effectively reinstates the unlawful blanket refusal on the substance. Reliance on s.31(3) as a fallback appears contrived to perpetuate non-disclosure. The request concerns police escort arrangements for a high-profile public event\/figure (Taylor Swift), aspects of which are often in the public domain. The AGO provides no specific, evidence-based prejudice from mere confirmation\/denial of holding further information. This piecemeal approach (disclose minor elements, NCND the rest) frustrates the tribunal's intent for comprehensive satisfaction of s.1(1)(a) and disclosure where possible, without reinstating the struck-down position. The substituted Decision Notice imposed a clear, binding obligation on the AGO as a public authority. The response represents wilful (or at least culpable) disobedience by effectively circumventing the tribunal's ruling through re-application of the quashed exemption and invocation of alternatives without adequate justification. If these proceedings were before a court with contempt powers, such failure to comply with a specific judicial order would constitute contempt (wilful disobedience or interference with justice). Certification is necessary to uphold the authority of the tribunal, ensure compliance with its orders, and protect the effectiveness of the FOIA regime. Public authorities must treat substituted decisions seriously; failure to do so undermines public trust in access to information rights.\u201d 8. The AGO\u2019s response to the application, dated 17 March 2026, made the following points, in summary: a. The AGO\u2019s response to the SDN was to issue a fresh response to the Applicant which complied with section 1(1)(a) of FOIA. b. The SDN did not clearly and unambiguously prohibit the AGO from relying on an NCND response, either in reliance on section 35(3) or 31(3); it only required the AGO to issue a fresh response to the Applicant which complied with section 1(1)(a) of FOIA. c. Similarly, the SDN did not clearly preclude reliance on any of the NCND provisions of FOIA. Lawful reliance on these provisions results in compliance with section 1(1)(a) of FOIA. d. The argument that the SDN should be read as precluding reliance on section 35(3) of FOIA because the Decision found that the AGO was not entitled to rely on this provision in its original response is unfounded. There is no clear prohibition in the Decision and that finding applied to different circumstances. Section 31 was not relied on in the AGO\u2019s original response, or raised in the appeal, so the SDN cannot be read as prohibiting the AGO from relying on it in future. e. The premise of the Decision was that the AGO misdirected itself as to the scope of the request and the SDN required it to redirect itself properly on scope to provide a response, the consequence of which would be to allow reliance on any relevant FOIA exemption or exception. f. If the Tribunal finds that there was a breach capable of constituting contempt, that breach did not amount to wilful non-compliance with the SDN. g. To the extent that the IC adopted the wrong approach in providing a fresh decision under section 1(1)(a), there is no need for certification; it is open to the Applicant to appeal the Fresh Response to the IC and, in turn to the Tribunal, at which point any arguments around whether or not the AGO should be allowed to revisit reliance on section 35 could be addressed. It is proportionate to address those arguments at that stage, because it may be that reliance on section 31 is upheld, meaning there is no need to consider section 35. h. The technical dispute between the parties as to the nature of \u201cgateway\u201d proceedings should be considered in the context of substantive proceedings, not certification application. 9. The Applicant filed a reply dated 19 March 2026 to the AGO\u2019s response in these proceedings. In summary he made the following points: a. Once the Tribunal has ruled that NCND is not justified and has substituted a decision notice requiring compliance with section 1(1)(a) FOIA, the public authority must confirm or deny whether it holds the requested information. It cannot simply re-deploy an NCND response (under the same or a different exemption) in the fresh response ordered by the Tribunal. In support of this the Applicant cited two cases of the First-tier Tribunal (\u201cFTT\u201d), Elsbury v IC [2025] UKFTT 915 (GRC) and Lawrence Dunhill v IC and Bolton NHS Foundation Trust [2025] UKFTT 1433 (GRC). b. The SDN did not permit the AGO to re-deploy an NCND response for any exemptions. The AGO\u2019s Fresh Response was in clear breach of the SDN. c. The SDN, read with the full Decision, was clear and unambiguous. The Decision forbade the use of section 35(3). No reasonable public authority could have read the SDN as permitting it to re-apply NCND under any exemption, whether the same one or a new one, in the fresh response. d. The obligations under the SDN were: i. To inform the Applicant in writing whether the AGO holds information of the description specified in the request; and ii. If information was held, either to disclose it or to state any and every legal ground for declining to do so. e. The Fresh Response was not compliance with the SDN. It was \u201ca deliberate failure to inform the Applicant whether the AGO held the remaining information specified in the request.\u201d The AGO consciously chose to respond in this way and did not apply to the Tribunal for clarification. f. The Applicant complains of the \u201cnear-endless loop\u201d of an unhappy recipient of a fresh response under an SDN having to complain to the IC again under section 50, with onward right of appeal to the Tribunal until all NCND responses have been dealt with by the Tribunal. He comments \u201cParliament cannot have intended FOIA to operate in such a circular and oppressive manner.\u201d g. The AGO could have joined the original appeal; it cannot now under a fresh response ordered by the Tribunal introduce NCND under section 31(3) as a means of circumventing the SDN. h. The SDN was \u201cobjectively clear\u201d and the AGO\u2019s conduct \u201ca calculated attempt to frustrate the Tribunal\u2019s ruling\u201d. Accordingly, the conduct was a clear breach capable of amounting to contempt. Witness evidence 10. The Tribunal had before it the witness statement of Rebecca Handler, Deputy Director and Head of the Domestic Law team at the AGO dated 18 March 2026. She states that she prepared the Fresh Response and explained why the AGO had adopted the approach it did to the use of NCND exemptions Applicable law 11. Where the FTT has substituted a decision notice for that of the\u00a0IC, the FTT\u00a0is responsible for\u00a0enforcing that substituted decision. This was decided by the Upper Tribunal in\u00a0Information Commissioner v Moss and the Royal Borough of Kingston upon Thames\u00a0[2020] UKUT 174 (AAC) (\u201cMoss\u201d).\u00a0 12. The relevant law is contained in section 61 of FOIA:\u00a0 \u201c(1) Tribunal Procedure Rules may make provision for regulating the exercise of rights of appeal conferred by sections 57(1) and (2) and 60(1) and (4)\u2026\u2026 (3) Subsection (4) applies where \u2013 (a) a person does something, or\u00a0fails to\u00a0do something, in relation to proceedings before the First-tier Tribunal on an appeal under those provisions, an (b) if those proceedings were proceedings before a court having power to commit for contempt, the act or omission would constitute contempt of court. (4) The First-tier Tribunal may certify the offence to the Upper Tribunal. (5) Where an offence is certified under subsection (4), the Upper Tribunal may \u2013 (a) inquire into the matter, and (b) deal with the person charged with the offence in any\u00a0manner in which\u00a0it could deal with the person if the offence had been committed in relation to the Upper Tribunal.\u201d 13. As confirmed in\u00a0Moss, the FTT does not have power\u00a0to compel a public authority to\u00a0comply with\u00a0a substituted decision notice or\u00a0to\u00a0actually commit\u00a0for\u00a0contempt, but\u00a0does have the power under these provisions to certify an offence to the Upper Tribuna Under section 61(4) FOIA, the FTT has a discretion to certify an offence to the Upper Tribunal only where it is satisfied that the requirements of both limbs of section 61(3) have been met i.e. that \u201ca person\u201d has done something or failed to do something in relation to proceedings before the Tribunal in appeals brought pursuant to sections 57 or 60 of FOIA and, if the proceedings were proceedings before a court having power to commit for contempt, the act or omission would constitute contempt of court.\u00a0 14. There is no mention in FOIA as to the required standard of proof by which the allegation of contempt must be judged. In the ordinary course, given the seriousness of contempt proceedings, the standard of proof by which the contempt must be\u00a0demonstrated\u00a0is the criminal standard of beyond reasonable doubt.\u00a0 15. If such an offence is proven to the required standard, the Tribunal must then consider whether, in all the circumstances of the case, discretion should be exercised\u00a0so as to\u00a0certify the offence to the Upper Tribunal.\u00a0 16. In\u00a0Navigator Equities Limited v Deripaska\u00a0[2021] EWCA\u00a0Civ\u00a01799, the Court of Appeal set out a helpful summary of general propositions of law in relation to contempt, which it considered to be \u201cwell-established\u201d:\u00a0 \u201c(i).\u00a0The bringing of a committal application is\u00a0an appropriate\u00a0and legitimate means, not only of seeking enforcement of an order or undertaking, but also (or alternatively) of drawing to the court's attention a serious (rather than purely technical) contempt. Thus, a committal application can properly be brought in respect of past (and irremediable) breaches.\u00a0 (ii).\u00a0A committal application must be proportionate (by reference to the gravity of the conduct alleged) and brought for legitimate ends. It must not be pursued for improper collateral purpose.\u00a0\u2026\u2026\u00a0 (v) It is\u00a0generally no\u00a0defence that the order disobeyed (or the undertaking breached) should not have been made or accepted.\u00a0 (vi) Orders and undertakings must be\u00a0complied with\u00a0even if compliance is burdensome,\u00a0inconvenient\u00a0and expensive. If there is any obstacle to compliance, the proper course is to apply to have the order or undertaking set aside or varied.\u00a0 (vii) In order to\u00a0establish\u00a0contempt, it need not be\u00a0demonstrated\u00a0that the contemnor intended to breach an order or undertaking and\/or believed that the conduct in question\u00a0constituted\u00a0a breach.\u00a0Rather it\u00a0must be shown that the contemnor deliberately intended to commit the act or omission in question. Motive is irrelevant.\u00a0 (viii) Contempt proceedings are not intended as a means of securing civil compensation.\u00a0 (ix) For a breach of order or undertaking to be established, it must be shown that the terms of the order or undertaking are clear and unambiguous; that the respondent had proper notice; and that the breach is clear (by reference to the terms of the order or undertaking).\u00a0\u201c 17. The Upper Tribunal case of\u00a0Penny Bence v Cornwall Council & Anor\u00a0[2025] UKUT 420 (AAC)\u00a0summarised the role of the FTT in relation to an application for contempt in paragraph 96 as follows:\u00a0 \u201ca. The role of the FTT when deciding whether to exercise the certification power in section 61(4) FOIA is, firstly, to determine whether the relevant person has done something or failed to do something in relation to the appeal before it that by its nature is capable of constituting a contempt had it occurred in proceedings before a court or a tribunal with power to commit for contempt. It is not the FTT\u2019s role to decide whether a contempt has been committed; b. If the FTT concludes this is the position, then, secondly, it will\u00a0proceed\u00a0to consider its discretion to certify. In exercising this discretion it will consider, in particular, whether\u00a0the conduct in question is sufficiently serious as to\u00a0warrant\u00a0a contempt inquiry and\u00a0possibly sanction; c. At the first stage, in assessing whether the act or omission in question is capable of constituting a contempt had it occurred in proceedings before a court or a tribunal with power to commit for contempt, the FTT will bear in mind the ingredients of a civil contempt (which I address at paragraphs 104 \u2013 114 below); d. At the second stage, in exercising its discretion and forming a view as to the seriousness of the matter, the FTT will bear in mind the observations of Lewis LJ (paragraph 91 above); that whether the order was intentionally breached will be relevant to the way the conduct is viewed when it comes to the question of sanction (paragraphs 110 \u2013 114 and 127 below); that applications for contempt should not be disproportionate (paragraph 85 above); the other factors that may impact on the sanction that could be imposed (paragraphs 127 \u2013 128 below); and (where applicable) the role of contempt proceedings where orders are breached by public authorities (paragraphs 98 \u2013 101 below); e. The potential contempt described in the FTT\u2019s certification in effect\u00a0identifies\u00a0the \u201ccharge\u201d that the Upper Tribunal will then inquire into. Accordingly, it should be formulated with as much clarity as is reasonably possible, albeit not in a way that unduly circumscribes the latter\u2019s role of inquiring into the contempt (as the Upper Tribunal has no jurisdiction to inquire into matters that go beyond the terms of the FTT\u2019s certification).\u201d 18. The Upper Tribunal in Harron v Rotherham MBC & IC [2026] UKUT 48 (AAC) held that it is for the IC, not the FTT to decide whether a response to a substituted decision notice is compliant with FOIA. In that decision, UT Judge Stout gave the following reasons at paragraphs 37-43: \u201c37. First, because (as was observed in Moss and Bence), section 61(3)-(5) of FOIA do not make provision for the enforcement of substituted decision notices in that they do not provide power for the First-tier Tribunal to compel a public authority to comply with the notice. Rather, the sub-sections create a contempt jurisdiction for the First-tier Tribunal, to be operated by the Upper Tribunal upon the First-tier Tribunal certifying the offence for the Upper Tribunal\u2019s consideration. The purpose of the contempt jurisdiction is to further the administration of justice by protecting, and securing compliance with, the authority of the court or tribunal (see [25] above). 38. Secondly, and accordingly, where the potential contempt is breach of the Tribunal\u2019s order, the principles developed in relation to civil contempt in the ordinary courts apply. The focus is always on whether or not the order has been breached (see above [26]-[28]). As the Navigator principles make clear, the law of contempt does not create any secondary cause of action or open up any new substantive jurisdiction. Nor is it concerned with whether the \u2018spirit\u2019 of the order has been fulfilled (VietJet: above, [27]). Orders that are ambiguous or otherwise unclear cannot properly form the basis of a contempt application. A person can only be held in contempt if the order is clear onits face and the person has, by intentional act or omission, breached the order (intentional in this context meaning that the act or omission was intended: the person may be in contempt even if they did not intend to breach the order). 39. Thirdly, there is no provision in section 61 (or elsewhere in FOIA) giving the First-tier Tribunal primary responsibility for determining whether a public authority has complied with FOIA. The primary responsibility for determining whether a public authority has complied with FOIA lies with the IC under section 50: the First-tier Tribunal\u2019s jurisdiction is a secondary, appellate role (albeit one in which it \u2018stands in the shoes\u2019 of the IC once the appeal is before it). 40. Fourthly, it follows from my second and third points that, unless the substituted decision notice states in terms that the public authority must provide a response that \u2018complies\u2019 with FOIA, there is no mechanism by which the First-tier Tribunal may become responsible for making that assessment on an application for certification of contempt under section 61. I agree with Mr Knibbe and Mr Paines that there is ordinarily no room in the law of contempt for implying into an order a requirement that the body to whom the order is directed should provide a \u201clawful\u201d or \u201creasonable\u201d response (or similar). Doing so in most cases would introduce uncertainty as to the order\u2019s effect that will render it unsuitable as a basis for a contempt application. It would also cut across the scheme of the Act, which places the primary responsibility for determining whether a public authority has complied with FOIA on the IC. 41. Fifthly, if (notwithstanding my fourth point) a First-tier Tribunal were to specify in a substituted decision notice that the public authority must provide a response to the request that complies with FOIA, then in principle a response that failed to comply with FOIA could be made the basis of an application under section 61(3) and (4). However, a First-tier Tribunal could only properly certify a contempt in relation to a substituted decision notice in such terms if it was satisfied: (i) that the order was sufficiently clear in its effect as to be capable of forming the basis of a contempt application; and (ii) the First-tier Tribunal was, as a matter of discretion, satisfied that it was appropriate to certify the case for the consideration of the Upper Tribunal (see [29] above). 42. Sixthly, a substituted decision notice is still a decision notice (see Moss at [25] and [35]). It is relatively common under the FOIA regime for the IC (and, in turn, the First tier Tribunal) to determine (as happened in this case) that the public authority\u2019s initial reliance on a particular exception in Part II of FOIA, or on section 14 (vexatious or repeated requests), was not compliant with FOIA and to direct the public authority to provide a fresh response to the request not relying on that exception or section 14. In such cases, the public authority\u2019s revised response may rely on (other) exceptions in Part II of FOIA or otherwise raise issues that are wholly different to those that were considered by the IC or the First-tier Tribunal when considering the lawfulness of the public authority\u2019s initial reliance on section 14. In cases where the IC\u2019s initial decision notice has not been appealed, there is plainly no difficulty with the IC considering a complaint under section 50 in relation to the public authority\u2019s revised response: the public authority\u2019s response to the initial IC decision notice remains a response to a request made under section 1 of FOIA. In cases where the IC\u2019s initial decision is appealed and the First-tier Tribunal issues a substituted decision notice, then that isalso \u2018just\u2019 a decision notice, and the response to it also remains a response to a request made under section 1 of FOIA. It follows that there is no difficulty in principle with the IC considering a complaint under section 50 in relation to the response to that substituted decision notice. Indeed, that will normally plainly be the appropriate route given that the public authority\u2019s revised response will be relying on an exception that the First-tier Tribunal has not dealt with at all so as a matter of principle it is unlikely that the revised response could constitute a contempt of the Tribunal. It is only if, and to the extent that, the public authority fails to comply with the terms of First-tier Tribunal\u2019s order, such that it is appropriate to treat it as a contempt of the First-tier Tribunal, that section 61 certification becomes a way of dealing with the situation (or the appropriate way of dealing with the situation if the public authority fails to respond at all). 43. In the present case, I am satisfied that the First-tier Tribunal did not err in law in refusing Mr Harron\u2019s application under section 61. The First-tier Tribunal\u2019s Substituted DN required only that RMBC issue \u201ca fresh response to the Appellant\u2019s request, not relying on section 14\u201d. RMBC did that on 12 July 2024. It was therefore open to the First-tier Tribunal to conclude that RMBC had complied with the terms of its order and that this was not therefore a case that was capable of constituting a contempt so as to make it appropriate even to consider exercising the discretion to certify (see [29] above). The question of whether RMBC complied with FOIA in thus responding, and in particular whether it made an adequate search (applying the Bromley principles) was a matter that Mr Harron could make the subject of a complaint to the IC under section 50 of FOIA. And it will now be a matter for the First-tier Tribunal when Mr Harron\u2019s appeal against the IC\u2019s new decision notice is heard in March 2026.\u201d Procedural matters 19. Both parties consented to determining this application without a hearing. I consider that it is fair and just for the Tribunal to determine the application in this way 20. The Tribunal considered a bundle of 100 pages. Discussion and conclusions 21. The first step, as summarised in Bence, is to\u00a0determine whether the relevant person, here the AGO, has done something or failed to do something in relation to the appeal before it that by its nature\u00a0is capable of constituting\u00a0a contempt had it occurred in proceedings before a court or a tribunal with power to commit for contempt.\u00a0The Tribunal\u00a0has to\u00a0decide whether the conduct\u00a0is capable\u00a0of constituting\u00a0a contempt.\u00a0In considering this, I need to\u00a0take into account\u00a0the ingredients of a civil contempt which were discussed by the UT at paragraphs 104-114 of\u00a0Bence. 22. I have also had in mind the relevant passage of Navigator Equities, cited above which requires at (ix) that to establish a breach of an order, it must be shown that: a. The terms of the order or undertaking are clear and unambiguous; b. the respondent had proper notice; and c. the breach is clear (by reference to the terms of the order or undertaking). 23. I find that paragraph 2 of the SDN imposed requirements on the AGO to: a. \u201cdeliver a fresh response to the Appellant satisfying the requirements of FOIA s1(1)(a)\u201d; and b. \u201cif relevant information was held on the date of the original response, disclose the same or state any and every legal ground for declining to do so.\u201d 24. I also find as a matter of fact that the SDN also made no mention of section 35(3) or any other exemption, other than in general terms by requiring the Fresh Response to include legal grounds for declining to disclose the information sought. In my view, this was clear and unambiguous and did not restrict the AGO from relying on any exemption. 25. I am not persuaded by the Applicant\u2019s submission that the SDN did not permit the AGO to re-deploy an NCND response for any exemptions or that once the Tribunal has ruled that NCND is not justified and has substituted a decision notice requiring compliance with section 1(1)(a) FOIA, the AGO must confirm or deny whether it holds the requested information. Had this been what the Tribunal intended, I consider it would have made this clear on the face of the SDN by specifying that the AGO could not rely on any NCND; but it did not. I note that the cases of Elsbury and Dunhill, which the Applicant relies, although persuasive, are not binding on this Tribunal, as they are its own decisions. Neither appears to be directly on point, as the substituted decision notice in Elsbury allowed for the authority in question to serve a refusal notice under section 17 FOIA without fettering its ability to rely on any particular exemption and that in Dunhill simply required it to deliver a fresh response satisfying section 1(1)(a) FOIA. 26. By reference to the terms of the SDN, I do not consider that there is a clear breach of its terms on the face of it. The SDN is a stand-alone decision notice which is substituted for the previous decision of the IC; there is no requirement that it be construed in light of the Tribunal\u2019s reasoning elsewhere in the Decision, or that the Tribunal\u2019s decision on the previous Decision Notice is determinative of any fresh response issued under the SDN. In order to comply with it the only things the AGO had to do were deliver a fresh response compliant with section 1(1)(a) and, to the extent it was not disclosing relevant information in scope of the request, to state the grounds on which it did so. I find that as a matter of fact the Fresh Response dated 14 January 2026 did both of these things, in that a. it informed the Applicant in writing that it held information of the description specified in the request and disclosed it to him with redactions under section 40, with which the Applicant appears not to have taken issue; and b. Stated clearly that it was relying on the exemptions in section 35(3) and 31(1)(a) not to confirm or deny whether it holds other information sought. 27. I therefore find that having received notice of the SDN, the AGO did not fail to do an act required by the SDN. It is not in dispute that the AGO provided the Fresh Response within the time set by the SDN. 28. Accordingly, I find that there is no act or omission capable of constituting a contempt in these circumstances, so the first part of the test for certification under section 61 is not met and the application must fail. 29. Had I not so determined, then I would have gone on to find that, following Harron, where a substituted decision notice is issued by a Tribunal, this is a fresh decision against which a complaint may be made to the IC under section 50 FOIA and which does not fall to be considered by this Tribunal unless or until any finding by the IC is appealed in due course. The appropriate step for the Applicant if he is dissatisfied with the Fresh Response is accordingly to make a section 50 complaint, not seek certification. 30. The application for certification is refused.<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence v2.0 (The National Archives). Republication avec attribution. Computational analysis necessite accord complementaire.<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

NCN: [2026] UKFTT 00690 (GRC) Case Reference: FT\/EJ\/2026\/0002 First-tier Tribunal (General Regulatory Chamber) Information Rights Decided without a hearing Decision given on: 18 May 2026 Before JUDGE HARRIS Between EDWARD WILLIAMS Applicant and THE ATTORNEY GENERAL\u2019S OFFICE Respondent Decision: The Applicant\u2019s application for certification of the AGO to the Upper Tribunal for contempt is refused. REASONS Background to the application…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":[],"kji_country":[7608],"kji_court":[7609],"kji_chamber":[],"kji_year":[7610],"kji_subject":[7612],"kji_keyword":[9242,13402,7661,7636,9279],"kji_language":[7611],"class_list":["post-933197","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-first-tier-tribunal-general-regulatory-chamber-information-rights","kji_year-7610","kji_subject-fiscal","kji_keyword-contempt","kji_keyword-response","kji_keyword-section","kji_keyword-tribunal","kji_keyword-whether","kji_language-anglais"],"yoast_head":"\nEdward Williams v The Attorney General's Office - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/ar\/jurisprudences\/edward-williams-v-the-attorney-generals-office\/\" \/>\n<meta property=\"og:locale\" content=\"ar_AR\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Edward Williams v The Attorney General's Office\" \/>\n<meta property=\"og:description\" content=\"NCN: [2026] UKFTT 00690 (GRC) Case Reference: FT\/EJ\/2026\/0002 First-tier Tribunal (General Regulatory Chamber) Information Rights Decided without a hearing Decision given on: 18 May 2026 Before JUDGE HARRIS Between EDWARD WILLIAMS Applicant and THE ATTORNEY GENERAL\u2019S OFFICE Respondent Decision: The Applicant\u2019s application for certification of the AGO to the Upper Tribunal for contempt is refused. 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