{"id":561417,"date":"2026-04-14T21:56:46","date_gmt":"2026-04-14T19:56:46","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/christine-wyatt-v-the-information-commissioner-anor-2\/"},"modified":"2026-04-14T21:56:46","modified_gmt":"2026-04-14T19:56:46","slug":"christine-wyatt-v-the-information-commissioner-anor-2","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/en\/jurisprudences\/christine-wyatt-v-the-information-commissioner-anor-2\/","title":{"rendered":"Christine Wyatt v The Information Commissioner & Anor"},"content":{"rendered":"
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1. This appeal is against the Commissioner\u2019s Decision Notices (IC-324837-K2B5 and IC-357000-M8D7), both dated 6 February 2025. The Decision Notices held that the Second Respondent ("the Council") was entitled to rely upon Regulation 12(4)(b) (manifestly unreasonable exception) of the Environmental Information Regulations ("EIR") to refuse to comply with the Appellant\u2019s requests for information. 2. The Tribunal convened an oral hearing which was held remotely using HMCTS\u2019s Cloud Video Platform. Brief factual background 3. In 1922, Maindy Park in Cardiff was gifted by the Marquis of Bute to the Council subject to restrictive covenants to use the land only as a park, open space, recreation or playground. In 1966, Maindy Park was registered as a charity ("the Trust") of which the Council is the sole trustee. The Trust's objects reflect the 1922 covenants. 4. Maindy Park includes a velodrome, the last remaining structure of the 1958 Commonwealth Games hosted by Wales. Other major events have taken place there over the years, and world class cyclists have trained there. Several other recreational facilities have been constructed on the site, attracting many participants all year round from the local community and beyond. 5. Adjacent to Maindy Park is Cathays High School. As local education authority, the Council has been considering expansion of the school on Maindy Park. Such use of the land appears to be incompatible with the Trust's objects. 6. The Council has therefore been corresponding with the Charity Commission about a possible "land swap" whereby part of Maindy Park would be released from the Trust with an alternative site within Council ownership instead being designated for recreational use by Cardiff residents. 7. The Council's land swap proposal has proved controversial, stimulating the establishment of a local campaign group called "Save Maindy Park" ("SMP") of which the Appellant ("CW") is a member. The information requests and responses 8. The Commissioner's Decision Notices ("DNs") respond to CW's complaints about the Council's handling of her two information requests set out below: First request dated 1 March 2024 ("Request 1") \u201cAt full council on 25\/1\/24 the written question response from councillor Dan DE'ath, ref W1 stated the councils external solicitors acting for the trust sent a partial reply to the Charity Commission on the 27\/11\/23 following a request from them for further information in respect of the Maindy Park land swap application. Please can you provide a copy of the partial reply sent by the external solicitors acting for the trust.\u201d Second request dated 2 May 2024 ("Request 2") "At the full council on the 25\/1\/24 Councillor D'eath stated that a partial response had been sent to the Charity Commission on the 27\/11\/23 following 2 requests for further information in respect of the Maindy Park land swap application. In a letter dated 25\/4\/24 from the Council leader Huw Thomas he states that the Council has responded to all the Charity Commissions requests for further information to date on the Maindy Park land swap, and that this information was provided over 7 weeks ago to the Charity Commission. Please can you provide copies of all communications sent to the Charity Commission between 27\/11\/23 and 20\/3\/24 from the Council, Council acting as trustee, Geldards and Geldards acting as trustee." 9. The Council replied to Request 1 on 17 May 2024 and Request 2 on 13 June 2024. In each case, the Council refused to provide the requested information, citing section 36 of the Freedom of Information Act 2000 ("FOIA") (prejudice to the effective conduct of public affairs). The internal review and response 10. CW asked the Council to carry out an internal review of their refusal to disclose the information sought by Requests 1 and 2. In neither case was any outcome of such internal review provided. Complaint to the Commissioner 11. On 10 August 2024, CW complained to the Commissioner about the Council's refusal of her requests. 12. CW challenged the Council's view that her requests "were likely to cause a disproportionate cost and burden". She argued that as the Council had already provided the requested documents to the Commissioner, any cost would be minimal and certainly insufficient to engage the exception. 13. During his investigation, the Commissioner asked the Council to reconsider Requests 1 and 2 under EIR (rather than FOIA) because he considered the information requested to be environmental. 14. The Council therefore reconsidered and on 10 January 2025 issued a fresh response to Requests 1 and 2. The Council again refused to provide the requested information, this time under the following exceptions: EIR 12(4)(b) (manifestly unreasonable); EIR 12(4)(d) (material in the course of completion); EIR 12(5)(b) (course of justice); and EIR 12(5)(d) (confidentiality of proceedings). The Decision Notices 15. The Commissioner issued his two Decision Notices ("DN") on 6 February 2025. The Commissioner was provided with the requested information as well as further submissions by both CW and the Council. 16. Each DN concluded that the Council was entitled to refuse Requests 1 and 2 under EIR 12(4)(b) on the basis that they were manifestly unreasonable. 17. The Commissioner applied guidance that: (a) the exception is engaged where a request is vexatious or where the cost of compliance would be excessive, and found this case fell within the former category; (b) although recognising that CW was pursuing a serious purpose and that there was significant public interest in transparency about the proposed land swap and the Council\u2019s dealings with the Charity Commission, the Commissioner considered: i. that the value of further disclosure was reduced because a substantial amount of information was already in the public domain; and ii. the Charity Commission was providing independent scrutiny that would itself be published. 18. The Commissioner further concluded that the cumulative burden created by the relatively large number of related requests had become disproportionate to their value and that complying with Requests 1 and 2 would likely prompt further requests. 19. Applying the public interest test, the Commissioner accepted that there was strong public interest in disclosure but held that this was outweighed by the public interest in protecting the Council\u2019s limited resources from unreasonable requests. He found that the presumption in favour of disclosure under EIR did not displace the exception. Appeal to the Tribunal 20. On 25 February 2025, CW appealed each DN to the Tribunal. 21. CW submits that each DN was legally wrong in concluding that EIR 12(4)(b) applies and that the Commissioner ought to have exercised his discretion differently when weighing the public interest balance. 22. In support of her appeal, CW submitted various documents (all included in the Open Bundles), which the Tribunal has read and considered. 23. CW invites the Tribunal to set aside each DN and require the Council to disclose the requested information. The Law Section 1(1) FOIA: General Right of access to information held by public authorities Any person making a request for information held to a public authority is entitled \u2013 (a) To be informed in writing by the public authority whether it holds information of the description specified in the request, and (b) If that is the case, to have that information communicated to him. EIR 2: definition of "environmental information" 24. EIR 2(1) defines 'environmental information" as including information on "the state of the elements of the environment such as\u2026soil, land, landscape\u2026and factors\u2026 such as energy, noise\u2026affecting or likely to affect the elements of the environment\u2026" and "measures\u2026such as activities affecting or likely to affect the [above] elements and factors" EIR 5: access to environmental information held by public authorities 25. EIR 5(1) sets out a specific duty by public authorities to make environmental information available on request and EIR 5(2) provides this shall be "as soon as possible and no later than 20 working days after\u2026receipt of the request". EIR 12: exceptions to the duty to disclose environmental information 26. There are exceptions to public authorities\u2019 duty to make environmental information available. Those pertinent to this appeal are set out in EIR 12, the relevant parts of which provide: "12 (1) Subject to paragraphs (2), (3) and (9), a public authority may refuse to disclose environmental information requested if \u2013 (a) an exception to disclosure applies under paragraphs (4) or (5); and (b) in all the circumstances of the case, the public interest in maintaining the exception outweighs the public interest in disclosing the information. (2) A public authority shall apply a presumption in favour of disclosure. \u2026 (4) For the purposes of paragraph (1)(a), a public authority may refuse to disclose information to the extent that \u2013 (a) … (b) the request for information is manifestly unreasonable;..". 27. In assessing what is "manifestly unreasonable\u2019" under EIR 12(4)(b), we are bound by. the decision of the Upper Tribunal in Craven v Information Commissioner and DECC [2012] UKUT 442 (AAC) where Judge Wikeley said at para. 30: "…the meaning of the expression \u201cmanifestly unreasonable\u201d is essentially the same as \u201cvexatious\u201d." 28. In Information Commissioner v Devon County Council & Dransfield [2012] UKUT 440 (AAC) ("Dransfield"),, the Upper Tribunal identified four key issues were relevant when deciding whether a request is vexatious: (1) the burden (on the public authority and its staff); (2) the motive (of the requester); (3) the value or serious purpose (of the request); and (4) any harassment or distress (of and to staff). However, the Upper Tribunal said these four considerations were not exhaustive nor created a formulaic checklist: a holistic and broad approach was needed. 29. The Court of Appeal in Dransfield v Information Commissioner [2015] EWCA Civ 454 emphasised \u201c… the high standard set by vexatiousness…." 30. Under EIR 12(1)(b) a public authority is permitted to withhold information under the exceptions in EIR 12(4) and 12(5) only if the public interest in maintaining the exception outweighs the public interest in disclosing the information. The role of the Tribunal 31. Section 57 FOIA entitles either the requester or the relevant public authority to appeal to this Tribunal against the Commissioner\u2019s decision notice. 32. Under s. 58 FOIA, if the Tribunal considers that the decision notice was either wrong in law or, to the extent that the notice involved an exercise of discretion by the Commissioner he ought to have exercised it differently, the Tribunal shall either allow the appeal (or substitute the decision notice) or dismiss the appeal. 33. The Tribunal can also review any finding of fact on which the decision notice was based. The burden of proof 34. The burden of proof rests with CW, as appellant, in satisfying the Tribunal that the Commissioner\u2019s decision was legally wrong or involved an inappropriate exercise of discretion. Written Evidence 35. The parties had submitted written evidence to the Tribunal prior to the hearing, comprising two Open Bundles: 656 pages (including indices) in respect of Request 1 and 681 pages (including indices) in respect of Request 2. The panel additionally had access to two Closed Bundles, one in respect of each Request 1 and 2. 36. CW has not seen the Closed Bundles which have been withheld from her and the public in accordance with GRC Rule 14(6) and the Tribunal\u2019s Practice Direction on Closed Material. However, the panel has seen and considered those materials. 37. The Closed Bundle in respect of Request 1 comprises the following copies: (a) an email from Geldards to the Charity Commission dated 27 November 2023; (b) a lease of the Maindy Centre dated 30 November 2016; and (c) a Charity Commission Enquiry Form dated 23 December 2021. 38. The Closed Bundle in respect of Request 2 contains the following copies: (a) an email from Geldards to the Charity Commission dated 1 March 2024; and (b) the Maindy Park Trust's Accounts 2023. 39. In the Open Bundles are witness statements from four Council employees. The panel heard oral evidence from three of them. Oral Evidence Summary of oral evidence on behalf of the Appellant 40. CW challenges the Council's refusal to disclose the requested information on the following basis. 41. The Council failed to provide the Commissioner with proper, evidence-based justification for treating her requests as burdensome: no quantitative data was supplied to demonstrate cost or workload impact, despite the Commissioner requesting it. Publicly available data shows the Council had long-standing difficulties complying with FOIA\/EIR time limits well before the Maindy Park requests. Significant delays in responding to her requests led to CW's repeated chasers and follow-up requests. 42. CW's requests pursued a serious purpose, grounded in substantial public-interest concerns about the Council\u2019s stewardship of Maindy Park, a charitable trust. These concerns\u2014including unauthorised leasing, use, and disposal of charity land\u2014align with Charity Commission warnings to local authorities on these topics. Both the Charity Commission and Audit Wales acknowledged these as matters of genuine community concern. 43. Transparency about the Council\u2019s communications with the Charity Commission is crucial, particularly as regulatory casework is not routinely published and key governance issues came to light only through evidence supplied by the community. Although the Commissioner accepted that the requests had public value, it appears that the Council\u2019s assertions about diminished value and alternative scrutiny mechanisms were accepted without sufficient verification. 44. Reliance on EIR 12(4)(b) is unfounded and unsupported by evidence. CW\u2019s requests represent a very small proportion of the Council\u2019s overall FOIA\/EIR workload and were framed narrowly to minimise the burden of responding to them. The requests are specific, proportionate, and justified by a strong public interest in accountability and transparency. Summary of oral evidence on behalf of the Council 45. The Council\u2019s witnesses focused on: (1) operational burden (driven by volume, frequency, internal coordination and legal review), and (2) sensitivity\/timing (because the Charity Commission process was ongoing and the material was said to include confidential\/privileged communications). 46. Taken together, the Council\u2019s evidence was that it generally meets statutory FOIA\/EIR performance targets but asserted that CW\u2019s pattern of frequent, repetitive and follow-on requests about Maindy Park\u201442 requests since November 2021, including Requests 1 and 2\u2014has created a disproportionate cumulative burden across the Council, particularly Legal Services, requiring repeated senior legal scrutiny and diverting resources from other core functions. 47. The Information Request Manager considered that disclosure would not satisfy CW but would likely generate further requests, while Requests 1 and 2 were themselves complex and resource intensive, requiring Monitoring Officer involvement and legal meetings. His personal involvement in CW's requests had diverted him from important record management projects. 48. The Monitoring Officer approved refusal under multiple EIR exceptions, viewing Requests 1 and 2 as manifestly unreasonable due to their aggregated burden, the live and sensitive nature of the Charity Commission process, risks of misinterpretation of the information, and the inclusion of confidential and legally privileged material, notwithstanding the Council\u2019s general commitment to transparency and prior disclosures. 49. The Principal Solicitor considered that non-disclosure was justified while the Charity Commission\u2019s statutory process was ongoing. This would in due course have resulted in public disclosure, but as the Council's application for approval of the proposed land swap ceased to be actively pursued, it was ultimately neither determined nor withdrawn. Submissions Submissions on behalf of the Council 50. The Council's evidence justifies treating Requests 1 and 2 as manifestly unreasonable\/vexatious under EIR 12(4)(b) (alongside other exceptions originally relied on by the Council). 51. There are two limbs to the Council's reliance on EIR 12(4)(b): first, the number of requests is manifestly unreasonable; and secondly, the ongoing statutory process with the Charity Commission made disclosure of the requested information manifestly unreasonable. 52. The Council had initially relied on s.36 FOIA, supported by a Qualified Person\u2019s Opinion explaining that disclosure would prejudice the effective conduct of public affairs because the correspondence was under live consideration by the Charity Commission; disclosure would inhibit full and frank engagement with the regulator; and it would likely trigger further requests causing significant diversion of limited resources. 53. When the Commissioner required reconsideration under EIR, those same considerations applied. The Council argued that EIR 12(4)(b) requires consideration of all the circumstances; critically, at the time of Requests 1 and 2 a statutory Charity Commission process was ongoing, justifying treating these requests differently from CW\u2019s earlier requests. 54. CW\u2019s attempt to categorise her requests separately should be rejected: the requests were all connected; all arose after the formation of the SMP campaign group; and all related to Maindy Park. It was therefore reasonable to consider the requests cumulatively and to conclude, in line with ICO guidance on vexatiousness, that their context, history and burden rendered them unreasonable, particularly as some were complex and required extensive cross-departmental input. 55. The Tribunal was reminded to assess the Commissioner\u2019s DNs at the time they were made, not with hindsight, and to find that the Commissioner correctly applied the presumption in favour of disclosure and the public interest test, committing no error of law or discretion. 56. Alternatively, the Council relied on further EIR exceptions: EIR 12(4)(d) because Request 1 concerned material still in the course of completion during an ongoing regulatory process; EIR 12(5)(b) because the information was subject to legal advice privilege and disclosure would prejudice the course of justice; and EIR 12(5)(d) because the correspondence formed part of confidential regulatory proceedings requiring a protected space for full and frank communications. Submissions on behalf of the Appellant, CW 57. The Council failed to substantiate its reliance on EIR regulation 12(4)(b) because it produced no evidence quantifying the time or resources spent dealing with CW\u2019s requests. 58. The Council achieved a 90% performance rate in responding to FOIA\/EIR requests before CW\u2019s requests and maintained or slightly improved that rate after 2021, showing no cogent evidence of service impairment. 59. The Council\u2019s claims of legal professional privilege were unsustainable and reliance on the ongoing nature of the Charity Commission process was misplaced, particularly as that application has since been closed, removing any risk of prejudice to a live process. 60. Significant public interest factors include the misuse of charitable land as a school car park, the grant of a long lease without authorisation, and the Council\u2019s stated intention to use the land for school expansion contrary to restrictive covenants requiring recreational use for the benefit of the community. 61. The Council was not required to assume the role of sole trustee and its actions as such have damaged public trust and confidence in the charitable sector. 62. The Council\u2019s true concern was potential challenge by beneficiaries of the Trust to the Charity Commission: the fear of such scrutiny could not lawfully justify refusal under EIR 12(4)(b). Discussion Findings of fact 63. The panel first considered the relevant facts of this case. Based on all the evidence provided, the panel made the following findings of fact on the balance of probabilities. Those findings shown underlined below are disputed, and the panel\u2019s reasoning for each such finding is set out beneath the underlined text. (a) The information which the Council \u2018holds\u2019 within the scope of Requests 1 and 2 is summarised in paragraph 36 above. (b) The Council correctly treats as connected all CW's information requests as shown on the spreadsheet: i. while CW challenges the "lumping together" of all her requests, the panel considers it reasonable to do so on the basis that they all relate to Maindy Park (whether the expansion of the school; tourism, attractions and the new velodrome; and the Trust affecting the land as well as the Council's stewardship of it); and ii. on CW's own account, she submitted all her requests on behalf of the campaign group, SMP. (c) The spreadsheet shows 42 requests (including Requests 1 and 2) from CW between 9 December 2021 and 2 May 2024. During that nearly 29-month period, CW's requests averaged one-and-a-half per month. (d) During the relevant period, the Council received around 1500 FOIA\/EIR requests annually. Of these, CW's requests amounted to less than 1%. (e) Requests 1 and 2 were the only two of CW's 42 requests which received responses refusing disclosure based on EIR 12(4)(b). (f) The spreadsheet shows since Request 2 a further nine requests (the last dated 16 April 2025). Of these all but two were "granted in full". Of the two refused, one (also about correspondence with the Charity Commission) was refused under EIR 12(4)(b), the other s.43 FOIA. (g) The Council's percentage of responses to FOIA\/EIR requests has been unchanged (at around 90%) since CW started submitting her information requests. (h) No harassment, irritation or distress has been caused to staff by CW's requests or responding to them. (i) The Council has not demonstrated any disproportionate or unjustified burden arising from Requests 1 and 2 or from CW\u2019s requests generally: i. No evidence was produced of the cost of staff time or other quantified resource impact, and no such data had been collated by the Council. The DNs made the same finding. ii. Of the four Council witnesses, three provided no evidence of distraction of resources or disruption to other services, notwithstanding general assertions of significant disruption. iii. The remaining witness, the Council's Information Requests Manager, referred to his own reduced capacity to manage record\u2011centre projects due to time spent on CW\u2019s requests, but this impact was unquantified and the panel considered such stretching of his capacity was likely to have been exacerbated by the Council\u2019s chosen method of handling of the requests, particularly Requests 1 and 2. iv. Moreover, the witness accepted in oral evidence that FOIA\/EIR performance levels were unaffected and that any burden fell on the Council generally rather than the FOIA team specifically. v. Evidence was adduced from other service areas, including witnesses from legal, governance or property teams, but none of this evidence showed that they or their teams had borne any disproportionate or unjustified burden. (j) While at the date of the DNs the Charity Commission's consideration of the proposed Maindy Park land swap was ongoing, the case has since been closed without a determination. (k) There is no publication of any report or other information in the public domain about the Charity Commission's consideration of Maindy Park. (l) The Council's plans for Maindy Park generated considerable opposition from the local community, with 4000 people signing a petition; over 500 objecting to the school expansion; and over 90% objecting to the land swap. (m) There was a serious purpose to CW's requests including Requests 1 and 2 and, as admitted by the Council, some serious past failings on their part as regards the Trust. Is there an error of law in the Commissioner\u2019s Decision Notices? 64. Having made its findings of fact, the panel considered whether the DNs were in accordance with the law. The panel noted that it was bound by Craven which confirms that \u201cmanifestly unreasonable\u201d under EIR 12(4)(b) is essentially equivalent to \u201cvexatious\u201d under s.14 FOIA. Relevant principles 65. Drawing on ICO guidance, the panel identified the following relevant principles: (a) the threshold for establishing vexatiousness (and thus manifest unreasonableness) is a high one, and at least as high under EIR given the presumption of disclosure; (b) while a large volume of requests may indicate a tipping point, authorities should keep evidence logs and cannot rely on numbers alone; (c) the authority\u2019s own handling of earlier requests, including errors, delays or unclear responses, may undermine a vexatiousness argument; follow-up requests must be assessed in context; (d) a single focused request is less likely to be vexatious absent other factors; (e) the value or serious purpose of a request is material, particularly where issues have not already been fully scrutinised; and (f) critically, manifest unreasonableness concerns the nature and impact of the request, not the requester, and not any harm which might arise from disclosure. The nature of Requests 1 and 2 66. The panel found that in respect of Requests 1 and 2: (a) they were tightly focused, clearly defined by date and type, and would not have required extensive searches; (b) the complexity in responding arose largely from the Council\u2019s chosen handling process, including senior sign-off and legal involvement, rather than from the requests themselves; (c) further, the Council\u2019s initial treatment of the requests under FOIA rather than EIR materially increased the workload, a consequence not attributable to the requester or the nature of the requests. CW\u2019s requests overall 67. Although the overall number of CW\u2019s requests might initially suggest vexatiousness, closer analysis shows that: (a) most of CW's requests were answered in full, with few refusals; (b) many were follow-up requests, in several cases prompted by omissions, inaccuracies, delays or failures in the Council\u2019s earlier responses; (c) in that context, the panel did not consider such follow-ups unreasonable, still less manifestly unreasonable; and (d) there is a risk of double-counting requests when assessing volume if legitimate follow-up requests are included. Which requests are \u201cmanifestly unreasonable\u201d? 68. The panel considered that Requests 1 and 2: (a) could not plausibly be regarded as manifestly unreasonable in themselves, given their narrow scope and the fact that the time spent responding to them was largely a product of the Council\u2019s chosen approach; (b) nor was it persuasive to treat them as a \u201ctipping point\u201d, since only requests seeking Charity Commission correspondence were labelled vexatious; the majority of CW\u2019s other requests were granted in full; and with the exception of one (which again sought copy correspondence with the Charity Commission) no subsequent requests were treated as manifestly unreasonable despite the alleged collective burden of responding. The Council\u2019s handling of CW\u2019s requests 69. The panel found that the Council\u2019s reliance on FOIA concepts applicable to s. 36 \u2014particularly prejudice, confidentiality and ongoing processes\u2014continued even after the Commissioner directed reconsideration under EIR, though such considerations are irrelevant to EIR 12(4)(b). 70. This approach led to escalation within the Council before responding to CW's requests, including extensive senior and legal involvement. 71. The witness evidence indicated that the Council\u2019s concern was primarily with the timing and sensitivity of disclosure of the information sought by Requests 1 and 2 during an ongoing Charity Commission process, rather than with the burden of responding to the requests. 72. The panel rejects the Council\u2019s late argument that an ongoing statutory process could itself render disclosure manifestly unreasonable, considering that this would impermissibly import a FOIA-style prejudice test into EIR 12(4)(b). Conclusion on EIR 12(4)(b) 73. Applying Dransfield, the panel concluded that: (a) the Council had repeatedly asserted but failed to evidence any disproportionate or unjustified burden, and had itself adopted an unduly burdensome methodology for handling CW\u2019s requests; (b) CW\u2019s motive was found to be a legitimate public interest aim of holding the Council to account as sole trustee of charitable land; (c) the requests had a serious purpose; (d) neither harassment nor distress to staff was alleged or evidenced; and (e) taking a holistic approach and bearing in mind the presumption in favour of disclosure under EIR, the high threshold for EIR 12(4)(b) was not met and that the Commissioner erred in law in finding the exception engaged. Other EIR exceptions 74. In accordance with its Malnick duty, the panel briefly considered the Council\u2019s alternative reliance on EIR 12(4)(d), 12(5)(b) and 12(5)(d), and concluded that none were engaged: the correspondence sought was complete rather than draft material; legal professional privilege did not apply to letters sent to a third-party regulator; and no statutory or common law basis for confidentiality of the Charity Commission proceedings had been established. Outcome 75. As none of the relied-upon exceptions was engaged, the appeal is allowed and a substitute decision issued. Signed: Date: 6 April 2026 Judge A. Marks CBE(First-tier Tribunal Judge)<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

1. This appeal is against the Commissioner\u2019s Decision Notices (IC-324837-K2B5 and IC-357000-M8D7), both dated 6 February 2025. The Decision Notices held that the Second Respondent (“the Council”) was entitled to rely upon Regulation 12(4)(b) (manifestly unreasonable exception) of the Environmental Information Regulations (“EIR”) to refuse to comply with the Appellant\u2019s requests for information. 2. The Tribunal convened an oral hearing…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7609],"kji_chamber":[],"kji_year":[7610],"kji_subject":[7612],"kji_keyword":[7693,7692,7615,7617,7691],"kji_language":[7611],"class_list":["post-561417","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-first-tier-tribunal-general-regulatory-chamber-information-rights","kji_year-7610","kji_subject-fiscal","kji_keyword-charity","kji_keyword-council","kji_keyword-information","kji_keyword-public","kji_keyword-requests","kji_language-anglais"],"yoast_head":"\nChristine Wyatt v The Information Commissioner & Anor - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/en\/jurisprudences\/christine-wyatt-v-the-information-commissioner-anor-2\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Christine Wyatt v The Information Commissioner & Anor\" \/>\n<meta property=\"og:description\" content=\"1. This appeal is against the Commissioner\u2019s Decision Notices (IC-324837-K2B5 and IC-357000-M8D7), both dated 6 February 2025. The Decision Notices held that the Second Respondent ("the Council") was entitled to rely upon Regulation 12(4)(b) (manifestly unreasonable exception) of the Environmental Information Regulations ("EIR") to refuse to comply with the Appellant\u2019s requests for information. 2. The Tribunal convened an oral hearing...\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.com\/en\/jurisprudences\/christine-wyatt-v-the-information-commissioner-anor-2\/\" \/>\n<meta property=\"og:site_name\" content=\"Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Est. reading time\" \/>\n\t<meta name=\"twitter:data1\" content=\"22 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/christine-wyatt-v-the-information-commissioner-anor-2\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/christine-wyatt-v-the-information-commissioner-anor-2\\\/\",\"name\":\"Christine Wyatt v The Information Commissioner & Anor - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#website\"},\"datePublished\":\"2026-04-14T19:56:46+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/christine-wyatt-v-the-information-commissioner-anor-2\\\/#breadcrumb\"},\"inLanguage\":\"en-US\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/christine-wyatt-v-the-information-commissioner-anor-2\\\/\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/christine-wyatt-v-the-information-commissioner-anor-2\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/criminal-law-attorneys-in-paris-counsel-and-strategic-defense\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Jurisprudences\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/jurisprudences\\\/\"},{\"@type\":\"ListItem\",\"position\":3,\"name\":\"Christine Wyatt v The Information Commissioner & Anor\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/\",\"name\":\"Kohen Avocats\",\"description\":\"Ma\u00eetre Hassan Kohen, avocat p\u00e9naliste \u00e0 Paris, intervient exclusivement en droit p\u00e9nal pour la d\u00e9fense des particuliers, notamment en mati\u00e8re d\u2019accusations de viol. Il assure un accompagnement rigoureux d\u00e8s la garde \u00e0 vue jusqu\u2019\u00e0 la Cour d\u2019assises, veillant au strict respect des garanties proc\u00e9durales.\",\"publisher\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"en-US\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#organization\",\"name\":\"Kohen Avocats\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-US\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"contentUrl\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"width\":2114,\"height\":1253,\"caption\":\"Kohen Avocats\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/en\\\/#\\\/schema\\\/logo\\\/image\\\/\"}}]}<\/script>\n<!-- \/ Yoast SEO Premium plugin. -->","yoast_head_json":{"title":"Christine Wyatt v The Information Commissioner & Anor - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/kohenavocats.com\/en\/jurisprudences\/christine-wyatt-v-the-information-commissioner-anor-2\/","og_locale":"en_US","og_type":"article","og_title":"Christine Wyatt v The Information Commissioner & Anor","og_description":"1. 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