Brown v The Information Commissioner & Anor

Brown v The Information Commissioner & Anor

Statistical data drawn from documents created by court staff for the purposes of proceedings in a particular cause or matter is exempt from disclosure under section 32(1)(c) of the Freedom of Information Act 2000, regardless of its form or whether it identifies parties.

Parties
Appellant: Mr Brown; First Respondent: Information Commissioner; Second Respondent: Ministry of Justice
Jurisdiction
England and Wales
Judgment Date
25 May 2016
Procedural Posture
Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Freedom of Information, Court Records Exemption, Statistical Data Disclosure
Administrative Law Information Law Freedom of Information Court Records Exemption Statistical Data Disclosure

Case Brief

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Parties

Mr Brown

Appellant

Information Commissioner

First Respondent

Ministry of Justice

Second Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Does section 32(1)(c) of the Freedom of Information Act 2000 apply to statistical data drawn from court records?
  2. 2 Is statistical information exempt from disclosure under FOIA if it is derived from documents created by court staff for proceedings?

Ratio Decidendi

Statistical data drawn from documents created by court staff for the purposes of proceedings in a particular cause or matter is exempt from disclosure under section 32(1)(c) of the Freedom of Information Act 2000, regardless of its form or whether it identifies parties.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed.
  • The decision of the First-tier Tribunal dated 5 May 2015 stands.