# Case (FOI request). Clitheroe v Information Commissioner (2023) UKFTT 299 (GRC)

**URL:** <https://forum.mentalhealthlaw.co.uk/t/case-foi-request-clitheroe-v-information-commissioner-2023-ukftt-299-grc/1543>\
**Category:** MHLO updates\
**Created:** [17 March 2023 22:34 UTC](https://forum.mentalhealthlaw.co.uk/t/case-foi-request-clitheroe-v-information-commissioner-2023-ukftt-299-grc/1543 "2023-03-17T22:34:43Z")\
**Posts on this page:** 1\
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**Author:** ![MHLO](https://forum.mentalhealthlaw.co.uk/user_avatar/forum.mentalhealthlaw.co.uk/mhlo/32/24_2.png) [@MHLO](https://forum.mentalhealthlaw.co.uk/u/MHLO)\
**Post date:** [17 March 2023 22:34 UTC](https://forum.mentalhealthlaw.co.uk/t/case-foi-request-clitheroe-v-information-commissioner-2023-ukftt-299-grc/1543/1 "2023-03-17T22:34:43Z")

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— This appeal under s57 [Freedom of Information Act 2000](https://www.mentalhealthlaw.co.uk/Freedom_of_Information_Act_2000 "Freedom of Information Act 2000") concerned requested information about a review project associated with the work of associate hospital managers conducted by Verita Consultancy for Lancashire and South Cumbria NHS Foundation Trust. The Trust originally applied s36 (prejudice to the effective conduct of public affairs) to one part of the request and refused to comply another part under s12 (cost exceeds appropriate limit) but subsequently withdrew its reliance on those exemptions. The Trust had complied with s1(1) but had communicated some information outside the 20-working-day requirement so had breached s10(1). There had been an error of law but no action was required.

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Full details available at: [https://www.mentalhealthlaw.co.uk/Clitheroe\_v\_Information\_Commissioner\_(2023)\_UKFTT\_299\_(GRC)?id=170323-2209](https://www.mentalhealthlaw.co.uk/Clitheroe_v_Information_Commissioner_(2023)_UKFTT_299_(GRC)?id=170323-2209)