Cleasby v University of Exeter & Anor [2026] UKUT 187 (AAC) (08 May 2026)

Executive summary

The Upper Tribunal held that the University of Exeter was in contempt of court for failing to disclose information it had been ordered to produce by the First-tier Tribunal within 42 days of the 30 January 2024 decision. The University had eventually disclosed the information on 8 May 2025, admitted the earlier failure was contempt, and the UT imposed a £15,000 fine and ordered publication of the decision.

Key points

• Parties: Peter Cleasby v University of Exeter and the Information Commissioner; the dispute arose under the Freedom of Information Act 2000.
• Holding: the University was in contempt of court for not complying with the FTT disclosure order by the deadline.
• Reasoning: the UT accepted the University’s concession of contempt and treated the delayed disclosure as serious because compliance came more than a year late.
• Sanction: the UT imposed a £15,000 fine and publication of the contempt finding.
• No sanctions/export-control nexus: the case concerns information disclosure, tribunal compliance, and contempt powers, not sanctions, export controls, or national security controls.

Why it matters

The decision is relevant to sovereign-risk and compliance analysis because it shows that UK tribunals will enforce disclosure orders through contempt findings and monetary sanctions, including against public bodies. It also highlights that delay can defeat the practical value of information sought for public-interest reporting, which can matter in transparency disputes affecting politically sensitive institutions.

Implications

For litigation strategy, parties facing an FTT disclosure order should treat it as immediately binding and seek clarification or appeal rather than assume non-party status or partial disclosure excuses compliance. For compliance and enforcement teams, the case underscores the need for rapid internal escalation, accurate legal review of FOIA obligations, and documented corrective steps, because later apology and eventual disclosure did not prevent a contempt finding and fine.