“The Information Tribunal was correct in holding that the wording of s 32(2) of the Freedom of Information Act 2000 had a very wide scope. There was no right under the 2000 Act to disclosure of documents held by public authorities which had been placed in the custody of or created by a person conducting an inquiry or arbitration for the purposes of the inquiry or arbitration, even after the inquiry or arbitration had concluded; the documents fell under the absolute exemptions set out in s 32(2) of the Act, regardless of their content and the consequences of their disclosure, and notwithstanding the public interest in their disclosure. However, the exemption could be waived and the information could be released by inquiries and arbitrators when the public interest required it.”
WLR Daily, 22nd January 2010
Please note once a case has been fully reported in one of the ICLR series the corresponding WLR Daily summary is removed.