Paul Latham v The Information Commissioner & Anor

Paul Latham v The Information Commissioner & Anor

On the balance of probabilities, UCL does not hold information responsive to either FOIA request. UCL's searches were reasonable and sufficient, and there was no operative conflict of interest or motive to withhold information. The Commissioner's decisions were in accordance with the law.

Parties
Appellant: Paul Latham; First Respondent: The Information Commissioner; Second Respondent: University College London
Jurisdiction
England and Wales
Judgment Date
14 April 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeals dismissed
Legal Topics
Freedom of Information, Public Authority Records, Disclosure Obligations, Conflict of Interest
Administrative Law Information Rights Freedom of Information Public Authority Records Disclosure Obligations Conflict of Interest

Case Brief

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Parties

Paul Latham

Appellant

The Information Commissioner

First Respondent

University College London

Second Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether UCL holds information responsive to the appellant's FOIA requests
  2. 2 Whether UCL conducted sufficiently rigorous and reasonable searches for the requested information
  3. 3 Whether any conflict of interest affected the adequacy of UCL's searches or responses

Ratio Decidendi

On the balance of probabilities, UCL does not hold information responsive to either FOIA request. UCL's searches were reasonable and sufficient, and there was no operative conflict of interest or motive to withhold information. The Commissioner's decisions were in accordance with the law.

Court Disposition

Appeals dismissed