Styles v Information Commissioner & Anor [2025] UKFTT 1138 (GRC) (01 October 2025)

Styles v Information Commissioner & Anor [2025] UKFTT 1138 (GRC) (01 October 2025)

Disclosure of abstraction licence numbers alone does not, on the balance of probabilities, adversely affect national security or public safety under regulation 12(5)(a) EIR. Any risk arises only if further requests are made to the Environment Agency, which is itself subject to the same legal duties and exemptions. Therefore, the exemption is not engaged and the information must be disclosed.

Citation
[2025] UKFTT 1138 (GRC)
Parties
Appellant: Peter William Styles; First Respondent: Information Commissioner; Second Respondent: Affinity Water Limited
Jurisdiction
United Kingdom
Judgment Date
01 October 2025
Procedural Posture
Appeal Under Environmental Information Regulations 2004 / Final Judgment on the Papers
Outcome
Appeal allowed
Legal Topics
Environmental Information Regulations 2004, Public Authority Disclosure Obligations, National Security Exemption, Public Interest Test, Water Abstraction Licensing
Information Law Environmental Law Administrative Law Environmental Information Regulations 2004 Public Authority Disclosure Obligations National Security Exemption Public Interest Test Water Abstraction Licensing

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Parties

Peter William Styles

Appellant

Information Commissioner

First Respondent

Affinity Water Limited

Second Respondent

Procedural Posture

Appeal Under Environmental Information Regulations 2004 / Final Judgment on the Papers

Legal Issues

  1. 1 Whether disclosure of abstraction licence numbers would adversely affect national security or public safety under regulation 12(5)(a) EIR
  2. 2 Whether the public interest in maintaining the exception outweighs the public interest in disclosure
  3. 3 Whether the presumption in favour of disclosure applies

Ratio Decidendi

Disclosure of abstraction licence numbers alone does not, on the balance of probabilities, adversely affect national security or public safety under regulation 12(5)(a) EIR. Any risk arises only if further requests are made to the Environment Agency, which is itself subject to the same legal duties and exemptions. Therefore, the exemption is not engaged and the information must be disclosed.

Court Disposition

Appeal allowed

Orders

  • Affinity Water Limited must, within 35 days, provide the Appellant with a list of boreholes abstracting water from a chalk aquifer in its area, including Environment Agency abstraction licence numbers and the name of the nearest village or town if not apparent from the source name.
  • Affinity Water Limited is directed to supply a copy of this Decision to the Environment Agency.