Adam Davies v The Information Commissioner

Adam Davies v The Information Commissioner

The Tribunal held that the request was manifestly unreasonable due to its excessive breadth, the significant burden it would place on TfL, and the availability of relevant information already published. The Tribunal found that the entire request constituted environmental information, that the public interest in...

Source-derived case information.

Parties
Appellant: Adam Davies; Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
12 April 2024
Procedural Posture
Appeal (information Rights) / Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Freedom of Information, Manifestly Unreasonable Requests, Public Interest Test, Access to Environmental Information
Administrative Law Environmental Law Information Law Environmental Information Regulations Freedom of Information Manifestly Unreasonable Requests Public Interest Test Access to Environmental Information

Source-derived case record

Summary, issues, holding and outcome

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Parties

Adam Davies

Appellant

Information Commissioner

Respondent

Procedural Posture

Appeal (information Rights) / Judgment

Legal Issues

  1. 1 Whether the refusal of the information request under Regulation 12(4)(b) of the Environmental Information Regulations 2004 (manifestly unreasonable) was lawful
  2. 2 Whether the public interest in disclosure outweighed the public interest in maintaining the exception
  3. 3 Whether the presumption in favour of disclosure was properly applied

Ratio Decidendi

The Tribunal held that the request was manifestly unreasonable due to its excessive breadth, the significant burden it would place on TfL, and the availability of relevant information already published. The Tribunal found that the entire request constituted environmental information, that the public interest in maintaining the exception outweighed the public interest in disclosure, and that the presumption in favour of disclosure did not tip the balance. The appeal was therefore dismissed.

Court Disposition

Appeal dismissed