Peter Stead v The Information Commissioner

Peter Stead v The Information Commissioner

BFI did not hold the requested training materials at the time of the request, and was entitled to rely on section 43(2) FOIA to redact commercially sensitive information from contracts. The public interest in disclosure does not outweigh the commercial interests protected by the exemption.

Parties
Appellant: Peter Stead; Respondent: The Information Commissioner
Jurisdiction
England and Wales
Judgment Date
21 May 2025
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal refused
Legal Topics
Freedom of Information Act, Commercial Interests, Public Interest Test, Disclosure of Contracts
Information Rights Administrative Law Freedom of Information Act Commercial Interests Public Interest Test Disclosure of Contracts

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Parties

Peter Stead

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether BFI holds training materials within the scope of the FOIA request
  2. 2 Whether BFI was entitled to rely on section 43(2) FOIA to redact contract information
  3. 3 Scope of the original FOIA request regarding costs and contracts

Ratio Decidendi

BFI did not hold the requested training materials at the time of the request, and was entitled to rely on section 43(2) FOIA to redact commercially sensitive information from contracts. The public interest in disclosure does not outweigh the commercial interests protected by the exemption.

Court Disposition

Appeal refused

Orders

  • No steps are ordered