William Dixon v Information Commissioner & Anor

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

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Parties

William Dixon

Appellant

Information Commissioner

First Respondent

University of Durham

Second Respondent

Procedural Posture

Appeal / Final Judgment

  1. 1 Whether the University was entitled to aggregate the Appellant’s requests under Regulation 5 of the Fees Regulations
  2. 2 Whether the University was entitled to rely on section 12(2) of FOIA to refuse the Appellant’s requests
  3. 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