Rhys Blakely v The Information Commissioner & Anor

Rhys Blakely v The Information Commissioner & Anor

Disclosure of the withheld information would adversely affect defence, national security and/or public safety, particularly due to the risk of a 'mosaic effect' enabling malicious actors to exploit the information. The public interest in maintaining the exception outweighs the public interest in disclosure, given the potential for extremely serious consequences and the existence of alternative mechanisms for accountability and transparency.

Parties
Appellant: Rhys Blakely; First Respondent: The Information Commissioner; Second Respondent: Health and Safety Executive
Jurisdiction
England and Wales
Judgment Date
20 December 2024
Procedural Posture
Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Freedom of Information, Environmental Information Regulations, Public Interest Test, National Security, Public Safety, Regulatory Exemptions
Information Law Environmental Law National Security Law Freedom of Information Environmental Information Regulations Public Interest Test National Security Public Safety +1 more

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Parties

Rhys Blakely

Appellant

The Information Commissioner

First Respondent

Health and Safety Executive

Second Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether disclosure of information about safety incidents at CL4 laboratories would adversely affect defence, national security or public safety under EIR regulation 12(5)(a)
  2. 2 Whether the public interest in maintaining the exception outweighs the public interest in disclosure

Ratio Decidendi

Disclosure of the withheld information would adversely affect defence, national security and/or public safety, particularly due to the risk of a 'mosaic effect' enabling malicious actors to exploit the information. The public interest in maintaining the exception outweighs the public interest in disclosure, given the potential for extremely serious consequences and the existence of alternative mechanisms for accountability and transparency.

Court Disposition

appeal dismissed