Bristol City Council v The Information Commissioner & Anor

Bristol City Council v The Information Commissioner & Anor

The Tribunal found that the cumulative effect of the requests, including their volume, similarity, and context as part of a coordinated campaign, imposed an oppressive and disproportionate burden on the Council. The limited value and public interest in the information sought did not outweigh the burden and distress caused. Therefore, the Council was entitled to rely on regulation 12(4)(b) EIR to refuse the requests as manifestly unreasonable, and the public interest in maintaining the exception outweighed the interest in disclosure.

Parties
Appellant: Bristol City Council; First Respondent: The Information Commissioner; Second Respondent: Helen Powell
Jurisdiction
England and Wales
Judgment Date
09 October 2024
Procedural Posture
Appeal / Judgment
Outcome
Appeal allowed
Legal Topics
Environmental Information Regulations, Manifestly Unreasonable Requests, Freedom of Information, Public Interest Test, Vexatious Requests
Information Law Environmental Law Administrative Law Environmental Information Regulations Manifestly Unreasonable Requests Freedom of Information Public Interest Test Vexatious Requests

Case Brief

Summary, issues, holding and outcome

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Parties

Bristol City Council

Appellant

The Information Commissioner

First Respondent

Helen Powell

Second Respondent

Procedural Posture

Appeal / Judgment

Legal Issues

  1. 1 Whether Bristol City Council was entitled to rely on regulation 12(4)(b) of the Environmental Information Regulations 2004 to refuse the information requests as manifestly unreasonable
  2. 2 Whether the public interest in maintaining the exception outweighed the public interest in disclosure
  3. 3 Whether the requests formed part of a campaign imposing an oppressive burden on the Council

Ratio Decidendi

The Tribunal found that the cumulative effect of the requests, including their volume, similarity, and context as part of a coordinated campaign, imposed an oppressive and disproportionate burden on the Council. The limited value and public interest in the information sought did not outweigh the burden and distress caused. Therefore, the Council was entitled to rely on regulation 12(4)(b) EIR to refuse the requests as manifestly unreasonable, and the public interest in maintaining the exception outweighed the interest in disclosure.

Court Disposition

Appeal allowed

Orders

  • The appeal is allowed. Bristol City Council was entitled to rely on regulation 12(4)(b) EIR to refuse the requests.