Edward Williams v Information Commissioner & Anor

1. The Appellant made an application for permission to appeal the case management directions of Judge Armstrong-Holmes dated 9 March 2026. These directions made a Rule 14(6) order in relation to certain closed material, including the entirety of the closed witness statement provided by the Second Respondent.

2. The Appellant applied for a gist of this statement to be provided to him. I made an order accordingly on 16 March. On 23 March the Second Respondent provided a gist of the closed statement which set out the full text of parts A to C of the statement, and a summary gist of the remainder of the statement.

3. The Appellant says that there was no good reason for parts A to C to be kept in closed. He also says that the Tribunal failed to comply with Rule 14(8) and did not notify him that the application had been made.

4. I agree that parts A to C of the closed statement should not remain as closed material, as they had been disclosed in full by the Second Respondent in the gist. I have reviewed the original decision on this basis, set it aside and made a new order in relation to the closed witness statement.

5. Rule 14(8) says, “ Unless the Tribunal considers that there is good reason not to do so, the Tribunal must send notice that a party has made an application for a direction under paragraph (6) to each other party .” This does not require the notice to be sent before the application has been decided, and the Appellant was notified about the fact of the application when the Rule 14 order was sent on 9 March 2026.