Andrew Lownie v The Information Commissioner & Anor

Andrew Lownie v The Information Commissioner & Anor

On the balance of probabilities, the University of Southampton did not hold further information within the scope of the Appellant’s FOI requests beyond what was disclosed. The searches conducted were reasonable and adequate. The only redaction under section 40(2) FOIA was the name of the visitor from the Royal Household, which was lawfully applied. There was no error of law or discretion in the Commissioner’s Decision Notices.

Parties
Appellant: Andrew Lownie; First Respondent: The Information Commissioner; Second Respondent: The Council of the University of Southampton
Jurisdiction
England and Wales
Judgment Date
24 September 2024
Procedural Posture
Information Rights Appeal / Final Judgment After Full Hearing
Outcome
Appeals dismissed
Legal Topics
Adequacy of Search, Disclosure of Information, Section 1 FOIA, Section 40(2) FOIA, Scope of FOI Requests
Freedom of Information Administrative Law Adequacy of Search Disclosure of Information Section 1 FOIA Section 40(2) FOIA Scope of FOI Requests

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Parties

Andrew Lownie

Appellant

The Information Commissioner

First Respondent

The Council of the University of Southampton

Second Respondent

Procedural Posture

Information Rights Appeal / Final Judgment After Full Hearing

Legal Issues

  1. 1 Whether the University of Southampton held further information within the scope of the Appellant’s FOI requests beyond what was disclosed
  2. 2 Whether the searches conducted by the University were adequate and reasonable under FOIA
  3. 3 Whether the redactions under section 40(2) FOIA were lawfully applied

Ratio Decidendi

On the balance of probabilities, the University of Southampton did not hold further information within the scope of the Appellant’s FOI requests beyond what was disclosed. The searches conducted were reasonable and adequate. The only redaction under section 40(2) FOIA was the name of the visitor from the Royal Household, which was lawfully applied. There was no error of law or discretion in the Commissioner’s Decision Notices.

Court Disposition

Appeals dismissed