The First‑tier Tribunal (General Regulatory Chamber) has struck out an appeal brought by a member of the public after he failed to provide the basic information required to identify the nature of his challenge to the Information Commissioner.
In Georgian Constantin v Information Commissioner [2025] UKFTT 1614 (GRC), Judge Buckley ruled that the appeal should be struck out under rule 8(3)(a) of the Tribunal Procedure (GRC) Rules after the appellant did not comply with case management directions issued in October.
Mr Constantin had written to the Tribunal seeking disclosure of a flash drive from Staffordshire Police, stating that the Information Commissioner had refused to assist him. However, the Tribunal said it was **unclear whether the matter concerned a data protection complaint under section 166 of the Data Protection Act 2018, a Freedom of Information Act appeal, or another type of application.
The appellant did not submit a completed GRC1 form and failed to provide the information required by the Rules, including details of the decision or act being challenged. The Tribunal also noted that he had not supplied a copy of any ICO decision notice or correspondence relating to a section 166 complaint.
Case management directions issued on 30 October 2025 required Mr Constantin to resubmit a compliant notice of appeal within 28 days and warned that failure to do so could result in the proceedings being struck out. No response was received.
Judge Buckley said the Tribunal was unable to progress the case without clarity on the nature of the appeal and the relevant decision under challenge. Striking out the proceedings was therefore “in the interests of justice and proportionate”.
The judge noted that Mr Constantin may apply for reinstatement under rule 8(5) if he can explain his non‑compliance and provide the missing information, including the decision or correspondence on which the appeal is based.
