Mr X and The Defence Forces (The Defence Forces) [2022] IEIC 113885 (1 December 2022)

Mr X and The Defence Forces (The Defence Forces) [2022] IEIC 113885 (1 December 2022)

The Defence Forces were justified in withholding information redacted under section 37(1) as it constituted personal information not excluded by section 2 Paragraph (I), and the public interest did not outweigh privacy rights. The Defence Forces were not justified in withholding parts of record 12 under section 33(1) as the harm test was not met.

Citation
[2022] IEIC 113885
Parties
Applicant: Mr X; Respondent: The Defence Forces
Jurisdiction
Ireland
Judgment Date
01 December 2022
Procedural Posture
FOI Review / Decision of Information Commissioner Following Internal Review
Outcome
partly allowed, partly refused
Legal Topics
Personal Information Exemption, Security and Defence Exemption, Public Interest Test, Access to Records

Case Brief

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Parties

Mr X

Applicant

The Defence Forces

Respondent

Procedural Posture

FOI Review / Decision of Information Commissioner Following Internal Review

  1. 1 Whether the Defence Forces were justified in refusing access to records under sections 33(1) and 37(1) of the FOI Act.

Ratio Decidendi

The Defence Forces were justified in withholding information redacted under section 37(1) as it constituted personal information not excluded by section 2 Paragraph (I), and the public interest did not outweigh privacy rights. The Defence Forces were not justified in withholding parts of record 12 under section 33(1) as the harm test was not met.

Court Disposition

partly allowed, partly refused

Orders

  • Defence Forces to release record 12 in full.
  • Redactions under section 37(1) to remain.