The full judgment given on Wednesday (11 January) has not yet been published online, but a judgment summary states that the PSNI applied for access to the BBC's un-broadcast footage to try and help identify certain masked men.
The Belfast Recorder, Judge Burgess, was said to have dismissed the BBC's claims that it was being used by police as "investigative tools" but also rejected the PSNI's application.
The judgment summary states that, in his assessment, Judge Burgess was said to have "been given no indication as to the specific purpose of the material and how it is to be of substantial benefit".
"In order to make out the case the court would require a more detailed examination on a proper evidential basis in relation to the investigation undertaken to date, and could be undertaken; and the role, if any, that the BBC footage would play in that investigation.
"The Recorder therefore concluded that on the basis of the evidence presently before the court, he could not be satisfied that the condition of substantial value had been satisfied and refused the application."
The National Union of Journalists said it welcomed the decision, which general secretary Michelle Stanistreet described in a release as "extremely significant".
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