Is no comment an answer

Answer 1

It is regarded as one in legal circles.

If I might add to the above, in general "no comment" is usually a cop-out to avoid self incrimination or embarrassment, but sometimes is used to avoid the incrimination or embarrassment of someone else, in which case, I suppose, it is a noble answer, if not a real answer. In the first case, however, it is a coward's "answer" often used by shysters in a clumsy or dishonest (and usually obvious) attempt to hide ignorance of the subject or question at hand.