Christopher Williams v The Information Commissioner

Christopher Williams v The Information Commissioner

The Home Office was entitled to rely on section 12 FOIA as the estimated cost of complying with the request would exceed the statutory limit. The estimate was reasonable, based on evidence, and not implausible. The Home Office complied with its section 16 FOIA duty by suggesting revisions and managing expectations. The Information Commissioner's decision notice was in accordance with the law and discretion was exercised correctly.

Parties
Appellant: Christopher Williams; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
06 May 2026
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Section 12 FOIA Cost Limit, Section 16 FOIA Advice and Assistance, Public Authority Exemptions, Tribunal Appellate Jurisdiction
Freedom of Information Administrative Law Section 12 FOIA Cost Limit Section 16 FOIA Advice and Assistance Public Authority Exemptions Tribunal Appellate Jurisdiction

Case Brief

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Parties

Christopher Williams

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the Home Office was entitled to rely on section 12 FOIA to refuse the information request
  2. 2 Whether the Home Office complied with its section 16 FOIA duty to provide advice and assistance
  3. 3 Whether the Home Office's change of position regarding exemptions was permissible

Ratio Decidendi

The Home Office was entitled to rely on section 12 FOIA as the estimated cost of complying with the request would exceed the statutory limit. The estimate was reasonable, based on evidence, and not implausible. The Home Office complied with its section 16 FOIA duty by suggesting revisions and managing expectations. The Information Commissioner's decision notice was in accordance with the law and discretion was exercised correctly.

Court Disposition

Appeal dismissed