Aaron Walawalker v The Information Commissioner & Anor
Section 11 FOIA does not require disclosure of transcripts up to the cost limit; reasonable practicability is determined independently of section 12 and public interest; MCA is not obliged to provide transcripts as none exist and transcription would be unduly burdensome.
- Parties
- Appellant: Aaron Walawalker; First Respondent: The Information Commissioner; Second Respondent: The Maritime and Coastguard Agency (Department for Transport)
- Jurisdiction
- England and Wales
- Judgment Date
- 11 October 2024
- Procedural Posture
- Appeal / Final Judgment
- Outcome
- appeal dismissed
- Legal Topics
- Freedom of Information Act, Public Authority Obligations, Means of Communication, Reasonable Practicability, Public Interest
Case Brief
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Parties
Aaron Walawalker
Appellant
The Information Commissioner
First Respondent
The Maritime and Coastguard Agency (Department for Transport)
Second Respondent
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Whether section 11 of FOIA requires disclosure of transcripts up to the cost limit or only as far as reasonably practicable
- 2 Whether public interest should be considered in determining reasonable practicability under section 11
- 3 Whether previous provision of transcripts by MCA obliges similar disclosure in this case
Ratio Decidendi
Section 11 FOIA does not require disclosure of transcripts up to the cost limit; reasonable practicability is determined independently of section 12 and public interest; MCA is not obliged to provide transcripts as none exist and transcription would be unduly burdensome.
Court Disposition
appeal dismissed
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