Bryan Rylands v The Information Commissioner

Bryan Rylands v The Information Commissioner

Regulation 12(5)(e) was engaged as the withheld information was commercial, confidential, and disclosure would prejudice the Council's legitimate economic interests in ongoing tendering; the public interest in maintaining the exception outweighed the public interest in disclosure.

Source-derived case information.

Parties
Appellant: Bryan Rylands; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
07 August 2025
Procedural Posture
Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Environmental Information, Confidentiality of Commercial Information, Public Interest Test, Regulation 12(5)(e) Eirs
Information Rights Administrative Law Environmental Information Confidentiality of Commercial Information Public Interest Test Regulation 12(5)(e) Eirs

Source-derived case record

Summary, issues, holding and outcome

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Parties

Bryan Rylands

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the Council was correct to withhold information under regulation 12(5)(e) of the Environmental Information Regulations 2004
  2. 2 Whether the public interest favoured disclosure or maintaining the exception
  3. 3 Whether the Council breached regulation 11(4) by delaying its internal review response

Ratio Decidendi

Regulation 12(5)(e) was engaged as the withheld information was commercial, confidential, and disclosure would prejudice the Council's legitimate economic interests in ongoing tendering; the public interest in maintaining the exception outweighed the public interest in disclosure.

Court Disposition

appeal dismissed