Jonathan Armstrong v The Information Commissioner

Jonathan Armstrong v The Information Commissioner

The tribunal found the request was manifestly unreasonable due to its breadth and the burden it would place on the Council, especially given the substantial information already in the public domain and limited public interest demonstrated. The Council's refusal was justified under regulation 12(4)(b) and the appeal was dismissed.

Parties
Appellant: Jonathan Armstrong; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Environmental Information Regulations, Freedom of Information, Public Interest Test, Manifestly Unreasonable Requests

Case Brief

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Parties

Jonathan Armstrong

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

  1. 1 Whether the Council was correct to refuse the information request as manifestly unreasonable under regulation 12(4)(b) of the Environmental Information Regulations 2004
  2. 2 Whether the Council provided adequate advice and assistance under regulation 9
  3. 3 Whether the public interest favoured disclosure of the requested information

Ratio Decidendi

The tribunal found the request was manifestly unreasonable due to its breadth and the burden it would place on the Council, especially given the substantial information already in the public domain and limited public interest demonstrated. The Council's refusal was justified under regulation 12(4)(b) and the appeal was dismissed.

Court Disposition

Appeal dismissed