Hugh Denis Craddock v The Information Commissioner

Hugh Denis Craddock v The Information Commissioner

The Council's provision of access to digitised tithe maps at its records office satisfies the requirements of regulation 6(1)(b) EIR as the information is 'publicly available' and 'easily accessible'; neither EIR nor FOIA require provision in a particular electronic format if the information is already accessible;...

Source-derived case information.

Parties
Appellant: Hugh Denis Craddock; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
07 October 2024
Procedural Posture
Appeal / Upper Tribunal Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Freedom of Information Act, Disclosure of Public Information, Accessibility of Information, Statutory Interpretation
Administrative Law Environmental Law Freedom of Information Environmental Information Regulations Freedom of Information Act Disclosure of Public Information Accessibility of Information Statutory Interpretation

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Parties

Hugh Denis Craddock

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Upper Tribunal Judgment

Legal Issues

  1. 1 Whether environmental information held in electronic form must be supplied in that format or can be made available for inspection at premises
  2. 2 Proper construction of regulation 6(1)(b) of the Environmental Information Regulations 2004
  3. 3 Application of section 39 and section 21 of the Freedom of Information Act 2000

Ratio Decidendi

The Council's provision of access to digitised tithe maps at its records office satisfies the requirements of regulation 6(1)(b) EIR as the information is 'publicly available' and 'easily accessible'; neither EIR nor FOIA require provision in a particular electronic format if the information is already accessible; the appeal fails as no error of law was found in the First-tier Tribunal's decision.

Court Disposition

Appeal dismissed

Orders

  • The appeal is refused.
  • The decision of the First-tier Tribunal stands.