Sheelagh Casey-Hulme v The Information Commissioner & Anor

Sheelagh Casey-Hulme v The Information Commissioner & Anor

The request was manifestly unreasonable due to its breadth and the significant burden it would place on Defra's resources, with compliance estimated at over 122-300 hours. The public interest in maintaining the exception outweighed the public interest in disclosure, especially given the volume of information already in the public domain and the lack of incremental value from further disclosure. Human rights arguments under Articles 2 and 8 ECHR are not relevant to the EIR public interest test.

Parties
Appellant: Sheelagh Casey-Hulme; First Respondent: The Information Commissioner; Second Respondent: The Department for Environment, Food and Rural Affairs
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
Information Rights Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Environmental Information Disclosure, Manifestly Unreasonable Requests, Public Interest Test, Human Rights Relevance in EIR
Environmental Law Information Law Administrative Law Environmental Information Disclosure Manifestly Unreasonable Requests Public Interest Test Human Rights Relevance in EIR

Case Brief

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Parties

Sheelagh Casey-Hulme

Appellant

The Information Commissioner

First Respondent

The Department for Environment, Food and Rural Affairs

Second Respondent

Procedural Posture

Information Rights Appeal / Final Judgment

Legal Issues

  1. 1 Whether the request for information was manifestly unreasonable under regulation 12(4)(b) EIR due to cost and burden on Defra's resources
  2. 2 Whether the public interest in maintaining the exception outweighed the public interest in disclosure

Ratio Decidendi

The request was manifestly unreasonable due to its breadth and the significant burden it would place on Defra's resources, with compliance estimated at over 122-300 hours. The public interest in maintaining the exception outweighed the public interest in disclosure, especially given the volume of information already in the public domain and the lack of incremental value from further disclosure. Human rights arguments under Articles 2 and 8 ECHR are not relevant to the EIR public interest test.

Court Disposition

appeal dismissed

Orders

  • Defra entitled to withhold the requested information under regulation 12(4)(b) EIR