Supreme Court rejects FLA application for disclosure of IC investigative report

KINGSTON, Jamaica — The Supreme Court has rejected an application by the Firearm Licensing Authority (FLA) seeking access to an investigative report prepared by the Integrity Commission (IC) into allegations of corruption, impropriety and irregularities involving the storage of firearms and ammunition and the granting of firearm licences.

In a ruling delivered in chambers, Justice Tara Carr held that the report remains confidential under the Integrity Commission Act (ICA) until it is formally tabled in Parliament.

In refusing the application, Justice Carr found that disclosure of the report was unnecessary at this stage of the proceedings, noting that the court already had sufficient information to determine the issues arising at the leave stage.

According to a release from the Court Administration Division on Friday, the court found that the FLA was already aware of the nature of the investigation, the decision-makers involved and the grounds upon which it intended to challenge the process, including allegations of procedural unfairness and illegality.

Justice Carr noted that the judicial review proceedings are primarily concerned with the decision-making process of which the applicant was already aware.

The court further held that the Integrity Commission had satisfied its duty of candour by providing sufficient information regarding the investigation and the process undertaken.

The judge also rejected submissions that the report fell outside the confidentiality provisions of the Integrity Commission Act. The court concluded that reports prepared pursuant to section 54 of the Act remain subject to the confidentiality requirements imposed by section 53(3) until they are tabled in Parliament.

Justice Carr pointed out that the legislation criminalises the unauthorised disclosure of confidential investigative material and said it would be inappropriate for the court to order disclosure where Parliament has established a clear statutory framework governing confidentiality and the tabling of reports.

Accordingly, the court refused the application for disclosure.

However, the court granted leave to appeal the ruling. The substantive application for leave to seek judicial review is scheduled to be heard on September 17, 2026.