Antony Williams v The Information Commissioner

Antony Williams v The Information Commissioner

The BBC was entitled to rely on section 12 FOIA because it provided a reasonable, sensible, and realistic estimate, supported by cogent evidence, that the cost of compliance would exceed the statutory limit. The BBC also complied with its section 16 duty by providing reasonable advice and assistance to the appellant on how to refine the requests.

Parties
Appellant: Antony Williams; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
17 June 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Freedom of Information, Costs of Compliance, Advice and Assistance Duty, Public Authority Obligations
Information Law Administrative Law Freedom of Information Costs of Compliance Advice and Assistance Duty Public Authority Obligations

Case Brief

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Parties

Antony Williams

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the BBC was entitled to rely on section 12 of the Freedom of Information Act 2000 to refuse the requests on the basis that the cost of compliance would exceed the appropriate limit
  2. 2 Whether the BBC complied with its duty under section 16 of the Freedom of Information Act 2000 to provide reasonable advice and assistance

Ratio Decidendi

The BBC was entitled to rely on section 12 FOIA because it provided a reasonable, sensible, and realistic estimate, supported by cogent evidence, that the cost of compliance would exceed the statutory limit. The BBC also complied with its section 16 duty by providing reasonable advice and assistance to the appellant on how to refine the requests.

Court Disposition

Appeal dismissed