Murray v The Information Commissioner [2025] UKFTT 270 (GRC) (20 February 2025)

Murray v The Information Commissioner [2025] UKFTT 270 (GRC) (20 February 2025)

The Forestry Commission did not hold the earlier versions of the Detailed Desk Study report at the time of the request, either directly or through the Consultants, as the drafts were only accessible via a link and not downloaded or possessed by the Commission. There was no evidence to support the claim that the documents were held on behalf of the authority or that the authority was evading its disclosure obligations.

Citation
[2025] UKFTT 270 (GRC)
Parties
Appellant: Michael Murray; Respondent: The Information Commissioner
Jurisdiction
United Kingdom
Judgment Date
20 February 2025
Procedural Posture
Appeal / Final Decision on Papers
Outcome
appeal dismissed
Legal Topics
Environmental Information, Freedom of Information, Public Authority Obligations, Document Disclosure
Information Law Environmental Law Administrative Law Environmental Information Freedom of Information Public Authority Obligations Document Disclosure

Case Brief

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Parties

Michael Murray

Appellant

The Information Commissioner

Respondent

Procedural Posture

Appeal / Final Decision on Papers

Legal Issues

  1. 1 Whether the Forestry Commission held earlier versions of the Detailed Desk Study report within the meaning of the Environmental Information Regulations 2004 at the time of the request
  2. 2 Whether the Information Commissioner's decision that no further information was held was correct

Ratio Decidendi

The Forestry Commission did not hold the earlier versions of the Detailed Desk Study report at the time of the request, either directly or through the Consultants, as the drafts were only accessible via a link and not downloaded or possessed by the Commission. There was no evidence to support the claim that the documents were held on behalf of the authority or that the authority was evading its disclosure obligations.

Court Disposition

appeal dismissed