William Dixon v Information Commissioner & Anor
The University was entitled to aggregate the seven requests as they were sufficiently similar and appeared to be made in concert; the estimated cost of compliance exceeded statutory limits, justifying refusal under section 12(2) FOIA; the University complied with its section 16 obligation to provide advice and assistance.
- Parties
- Appellant: William Dixon; First Respondent: Information Commissioner; Second Respondent: University of Durham
- Jurisdiction
- England and Wales
- Judgment Date
- 12 March 2025
- Procedural Posture
- Appeal / Final Judgment
- Outcome
- Appeal dismissed
- Legal Topics
- Freedom of Information, Aggregation of FOI Requests, Cost Limits Under FOIA
Case Brief
Summary, issues, holding and outcome
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Parties
William Dixon
Appellant
Information Commissioner
First Respondent
University of Durham
Second Respondent
Procedural Posture
Appeal / Final Judgment
Legal Issues
- 1 Whether the University was entitled to aggregate the Appellant’s requests under Regulation 5 of the Fees Regulations
- 2 Whether the University was entitled to rely on section 12(2) of FOIA to refuse the Appellant’s requests
- 3 Whether the University complied with its section 16 FOIA obligation to provide advice and assistance
Ratio Decidendi
The University was entitled to aggregate the seven requests as they were sufficiently similar and appeared to be made in concert; the estimated cost of compliance exceeded statutory limits, justifying refusal under section 12(2) FOIA; the University complied with its section 16 obligation to provide advice and assistance.
Court Disposition
Appeal dismissed
Orders
- No further steps required by the University
- Decision Notice upheld
Full Case Text
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