A bloke named Charlie Adams took the NSW Police Commissioner to the Supreme Court after he was knocked back from getting a full, unedited police report. Mr Adams had found a security camera in the men’s toilet of a Sydney internet café and wanted the report for a personal injury lawsuit he was planning against the café owner. The police gave him a copy but blacked out bits of it, like the café’s address and the owner’s details, saying releasing that info wasn’t in the public interest. Mr Adams argued that the café owner was a potential wrongdoer and shouldn’t get the same confidentiality protections as a regular informant. After losing his case at the NSW Civil and Administrative Tribunal (NCAT) and then losing his appeal there too, he went to the Supreme Court. The Court looked at his arguments, especially about how the law on releasing government information should be read, but ultimately decided the Tribunal and its Appeal Panel had made the right call. The judge dismissed Mr Adams’s case but decided not to make him pay the police’s legal costs because the case raised some new and important legal questions for the public.
Key details of the case
- Case Name: Adams v Commissioner of Police, New South Wales Police Force
- Case Number: 2025/00143980
- Court: Supreme Court of New South Wales
- Judge: Griffiths AJ
- Hearing Date: 01 October 2025
- Decision Date: 9 October 2025
- Plaintiff: Charlie Armstrong Adams (representing himself)
- Defendant: Commissioner of Police, NSW Police Force (represented by C Langford)
- Incident Date: 27 June 2023
- Incident Location: An internet café in Sydney
- Initial Request for Information: 17 December 2023, under the Government Information (Public Access) Act 2009 (GIPA Act)
- Previous Decisions: The case was a judicial review of a decision made by the NSW Civil and Administrative Tribunal (NCAT) Appeal Panel on 21 March 2025, which had upheld an earlier NCAT decision from 2024.
Simple summary of the case
The whole thing kicked off when Charlie Adams found a security camera in the blokes’ bathroom at a Sydney internet café on 27 June 2023. He reported it to the police, who came out and made a report, known as a COPS Report. Later that year, Mr Adams decided he wanted to sue the café owner for personal injury and asked the police for a full copy of that report to help build his case. The police sent him the report, but with a fair few bits blacked out, or ‘redacted’. They’d removed details like the café’s location, the owner’s name and personal info, and what the owner said to the police. The police argued that keeping this information private was in the public interest for several reasons, mainly under a law called the GIPA Act. This law basically says that sometimes, keeping information confidential is more important than releasing it to the public.
Mr Adams wasn’t happy with this. He argued that the rules for confidentiality shouldn’t protect someone who might have broken the law. He believed the café owner was a ‘wrongdoer’, not a helpful informant, so hiding their details was wrong. He first took his complaint to an internal review with the police, then to the NSW Civil and Administrative Tribunal (NCAT), and when he lost there, he appealed to the NCAT Appeal Panel. The Appeal Panel also sided with the police, agreeing that releasing the information could stop people from providing confidential information to the police in the future, which would make their job harder. They also pointed out it would reveal personal details and business information that was protected.
Still not giving up, Mr Adams took the matter to the Supreme Court of NSW. He wasn’t just appealing again; he was asking for a ‘judicial review’, which means he was arguing that the NCAT Appeal Panel had made a legal mistake in how it made its decision. His main point was that the law, specifically a bit called clause 1(d) of the GIPA Act, was being misinterpreted. He felt the Appeal Panel didn’t properly consider that the café owner was the subject of the complaint, not a bona fide informant who needed protection. He also claimed the panel ignored that some of the blacked-out information could have been released without identifying anyone.
The Supreme Court judge, Griffiths AJ, looked very carefully at the law and the Appeal Panel’s decision. The judge found that the law doesn’t actually make a distinction between a ‘wrongdoer’ and an ‘innocent informant’. The rule is about protecting the supply of confidential information to government agencies in general, regardless of who provides it. The judge decided that the Appeal Panel had correctly understood and applied the law. It had properly weighed up the public interest in releasing the information against the public interest in keeping it private. The judge concluded that the Appeal Panel hadn’t made any legal errors. As a result, Mr Adams’s case was dismissed. You can read the full, detailed judgement from the Supreme Court here. However, in a final twist, the judge decided that because Mr Adams had raised a new and important legal question that hadn’t been tested in court before, it was a matter of public interest. Therefore, he ordered that each side should pay their own legal costs, meaning Mr Adams didn’t have to pay for the Police Commissioner’s lawyers.
Q&A
- Is it legal for someone to put a camera in a public toilet?
Generally, no. Placing a camera in a bathroom where people expect privacy is often illegal and can lead to serious criminal charges related to surveillance and privacy offences. - Can I get a copy of a police report if I was the one who reported the crime?
Yes, you have a right to ask for it under the GIPA Act. However, as this case shows, you might only get a redacted version if there are public interest reasons against disclosing certain details. - What does ‘redacted’ mean?
It means that parts of a document have been blacked out or removed to protect sensitive or confidential information before it’s released. - Why would the police redact information they give me?
They might do it to protect someone’s personal privacy, to protect confidential sources, to avoid harming someone’s business interests, or to prevent compromising an ongoing investigation. - Can I argue that the person whose details are redacted is a ‘wrongdoer’ and doesn’t deserve privacy?
You can argue it, but this case shows that the law (the GIPA Act) doesn’t distinguish between a ‘wrongdoer’ and an ‘informant’ when it comes to protecting the flow of confidential information to police. The focus is on the function, not the person’s character. - If I want information for a lawsuit, does that give me a better reason to get it?
It’s a factor that can be considered in your favour. However, the decision is still based on balancing all public interest factors, and your need for it doesn’t automatically override reasons against disclosure. - What if I already know the information that’s been blacked out?
It doesn’t matter. Information released under the GIPA Act is considered released ‘to the world’, not just to you. The decision is based on the impact of that information being fully public, not just on what you personally know. - What’s the difference between a merits review and a judicial review?
A merits review (like at NCAT) looks at the facts and decides if the original decision was the ‘correct and preferable’ one. A judicial review (at the Supreme Court) doesn’t re-examine the facts; it only looks at whether the decision-maker followed the law correctly and acted within their power. - Is it worth representing myself in court?
Mr Adams represented himself all the way to the Supreme Court. While it’s possible, court processes are very complex, and getting legal advice is highly recommended. - Can I get in trouble for sharing information I receive through a GIPA request?
No. The GIPA Act states that once you are given the information, the agency cannot place any conditions on how you use or share it. - If I lose a court case, do I always have to pay the other side’s legal costs?
Usually, the loser pays the winner’s costs. However, in this case, the judge made no order as to costs because the case raised a novel legal issue in the public interest. This is an exception, not the rule. - What is the ‘public interest test’?
It’s the process set out in the GIPA Act where a government agency must weigh the public interest reasons for releasing information against the public interest reasons for not releasing it. Information is only withheld if the reasons against disclosure outweigh the reasons for it. - Does finding a camera mean I can automatically sue and win?
Not automatically. You would still need to prove your case in court, including showing that the person you are suing was responsible and that you suffered harm or ‘personal injury’ as a result. - What should I do if I find a hidden camera in a public place?
Do not touch it. Report it to the police immediately and also inform the management of the premises. - Where can I find more simplified summaries of court cases?
For more easy-to-understand breakdowns of legal judgements, you can explore resources that specialise in this area. For other NSW Supreme Court cases, you might find something useful on websites that simplify legal content like these NSW Supreme Court Cases.