Ratio Decidendi
The qualified exemption under s.32 FOIA for information held by courts and inquiries continues to apply after proceedings have ended. Common law rights of access to information may supplement FOIA.
Facts
A journalist sought information held by the Charity Commission about its inquiries into the Mariam Appeal charity. The Commission refused under s.32.
Judgment Summary
The Supreme Court held that s.32 applied but explored whether common law transparency principles could require disclosure. The case established that the common law right to receive information exists alongside FOIA.
Key Quotes
"There is a common law presumption in favour of openness and transparency."
— Lord Mance
Subsequent Treatment
Applied
Cited in subsequent FOI and common law transparency cases.