An information-rights complaint can expose procedural fault even when the requested information ultimately remains withheld.
The Rotherham decision
A request concerned the Council’s investigation into alleged encroachment onto public land. The Council initially relied on Freedom of Information Act exemptions, but later accepted that the Environmental Information Regulations were the correct access regime.
The Commissioner accepted that the information could be withheld under regulation 12(5)(b), while finding breaches because the Council did not issue a refusal notice within 20 working days and did not handle the request under the EIR from the outset.
Black Sheep evidence lesson
Separate outcome from process. Ask: which information-access regime applies, when was the valid request received, when was the refusal issued, which exception was relied on and was the required reasoning provided? A complaint can be partly successful without resulting in disclosure.