Edward Williams v The Information Commissioner & Anor

Edward Williams v The Information Commissioner & Anor

Section 27 FOIA is engaged for information highlighted in yellow, as disclosure would likely prejudice UK international relations and interests abroad. The public interest in maintaining the exemption outweighs the public interest in disclosure. Section 36 FOIA is not engaged for information highlighted in green, as the qualified person's opinion was not reasonable and lacked evidential basis. Section 40(2) FOIA applies to personal data, as disclosure is not necessary for the applicant's legitimate interests.

Parties
Appellant: Edward Williams; 1st Respondent: The Information Commissioner; 2nd Respondent: The Foreign, Commonwealth and Development Office
Jurisdiction
England and Wales
Judgment Date
03 February 2026
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal allowed in part
Legal Topics
Freedom of Information, International Relations, Personal Data, Public Interest Immunity
Administrative Law Information Law Freedom of Information International Relations Personal Data Public Interest Immunity

Case Brief

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Parties

Edward Williams

Appellant

The Information Commissioner

1st Respondent

The Foreign, Commonwealth and Development Office

2nd Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether section 27 FOIA (international relations) exemption applies to the withheld information
  2. 2 Whether section 36 FOIA (prejudice to effective conduct of public affairs) exemption applies to the withheld information
  3. 3 Whether section 40(2) FOIA (personal data) exemption applies to the withheld information

Ratio Decidendi

Section 27 FOIA is engaged for information highlighted in yellow, as disclosure would likely prejudice UK international relations and interests abroad. The public interest in maintaining the exemption outweighs the public interest in disclosure. Section 36 FOIA is not engaged for information highlighted in green, as the qualified person's opinion was not reasonable and lacked evidential basis. Section 40(2) FOIA applies to personal data, as disclosure is not necessary for the applicant's legitimate interests.

Court Disposition

Appeal allowed in part

Orders

  • FCDO to disclose the information highlighted in green in the document starting at page 50 in the closed bundle within 35 days.
  • FCDO entitled to withhold information highlighted in yellow under section 27 FOIA.