Howard Liu v Information Commissioner

Howard Liu v Information Commissioner

The request was not manifestly unjustified, inappropriate, or improper; there was no evidence of improper motive, harassment, or excessive burden, and the request had reasonable foundation and public interest. Section 14(1) FOIA could not be relied upon to refuse the request.

Parties
Appellant: Howard Liu; Respondent: Information Commissioner
Jurisdiction
England and Wales
Judgment Date
25 July 2025
Procedural Posture
Appeal / Final Judgment
Outcome
appeal allowed
Legal Topics
Freedom of Information Act 2000, Vexatious Requests, Public Interest, Burden of Compliance
Information Rights Administrative Law Freedom of Information Act 2000 Vexatious Requests Public Interest Burden of Compliance

Case Brief

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Parties

Howard Liu

Appellant

Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether the British Library was entitled to rely on section 14(1) FOIA to refuse the information request
  2. 2 Whether the request was vexatious under section 14 FOIA

Ratio Decidendi

The request was not manifestly unjustified, inappropriate, or improper; there was no evidence of improper motive, harassment, or excessive burden, and the request had reasonable foundation and public interest. Section 14(1) FOIA could not be relied upon to refuse the request.

Court Disposition

appeal allowed

Orders

  • The British Library must comply with section 1(1) FOIA and respond to the request within 35 days, stating whether it holds the requested information and either supply the information or serve a notice under section 17 FOIA relying on grounds other than section 14(1).