Black v NSW Police Force [2008] NSWADT 177

Black v NSW Police Force [2008] NSWADT 177

The Tribunal determined that the document was exempt as it contained information enabling the existence or identity of a confidential source relating to law enforcement to be ascertained, and that discretionary considerations also favoured refusal of access to avoid hindering the police's ability to administer firearm laws effectively.

Parties
Applicant: Phillip Ross Black; Respondent: NSW Police Force
Jurisdiction
Australia
Judgment Date
19 June 2008
Procedural Posture
Application for Review of FOI Determination / Final Decision
Outcome
application dismissed; access to the document refused
Legal Topics
Access to Documents, Confidential Sources, Discretion to Grant Access

Case Brief

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Parties

Phillip Ross Black

Applicant

NSW Police Force

Respondent

Procedural Posture

Application for Review of FOI Determination / Final Decision

  1. 1 Whether the document under review is an exempt document under the Freedom of Information Act 1989 (NSW) Schedule 1
  2. 2 Whether the applicant should be granted access to the document on discretionary grounds

Ratio Decidendi

The Tribunal determined that the document was exempt as it contained information enabling the existence or identity of a confidential source relating to law enforcement to be ascertained, and that discretionary considerations also favoured refusal of access to avoid hindering the police's ability to administer firearm laws effectively.

Court Disposition

application dismissed; access to the document refused

Orders

  • The document under review is an exempt document
  • Access to the document under review is refused