A journalist had requested the appellant who published the claims made by Members of Parliament for expenses to its website had requested in addition copies of the receipts produced by the MPs to justify three claims. The Authority provided a narrative from the receipts but declined to provide copies. The information Commissioner, and tribunals required … Continue reading The Independent Parliamentary Standards Authority v The Information Commissioner and Another: CA 28 Apr 2015
Mrs Nolan had been employed at a US airbase. When it closed, and she was made redundant, she complained that the appellant had not consulted properly on the redundancies. The US denied that it had responsibility to consult, and now appealed. Held: The appeal failed (Lord Carnworth dissenting). That the exact situation might not have … Continue reading The United States of America v Nolan: SC 21 Oct 2015
Presumption in Favour of Open Proceedings There had been an unauthorised dissemination by the petitioner to third parties of the official shorthand writer’s notes of a nullity suit which had been heard in camera. An application was made for a committal for contempt. Held: The House equated the contempt to a breach of an injunction … Continue reading Scott v Scott: HL 5 May 1913
Citations:  UKFTT 2015 – 0066 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 11 June 2022; Ref: scu.552484
Citations:  UKFTT EA – 2012 – 0249 (GRC Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 11 June 2022; Ref: scu.517846
Citations:  UKFTT EA – 2012 – 0141 (GRC Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 11 June 2022; Ref: scu.517845
The claimant and her son sought to visit her other son in Leeds Prison. He was suspected of involvement in drugs, and therefore she was subjected to strip searches. There was no statutory support for the search. The son’s penis had been touched which was a battery. Held: The policy considerations which limit the heads … Continue reading Wainwright and another v Home Office: HL 16 Oct 2003
The claimant journalist sought disclosure of papers acquired by the respondent in its conduct of enquiries into the charitable Mariam appeal. The Commission referred to an absolute exemption under section 32(2) of the 2000 Act, saying that the exemption continued until the papers were destroyed, or for 20 years under the 1958 Act. Held: The … Continue reading Kennedy v The Charity Commission: SC 26 Mar 2014
Citations:  UKFTT EA – 2011 – 0118 Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 31 May 2022; Ref: scu.578284
The council had taken the applicant’s children into care alleging that the mother had harmed them. In the light of the subsequent cases casting doubt on such findings, the mother sought the return of her children. She applied now that the hearings be in public. Held: The applicant and her solicitors had already made significant … Continue reading Kent County Council v The Mother, The Father, B (By Her Children’s Guardian); Re B (A Child) (Disclosure): FD 19 Mar 2004
The court was asked whether the daughter of Cecil Parkinson and Sarah Keays should be permitted to take part in a television programme about the specialist help she was receiving for her special educational needs. Held: The court refused to vary an injunction against publication of any details with regard to a particular child. This … Continue reading In re Z (A Minor) (Identification: Restrictions on Publication): CA 31 Jul 1995
The court did not have power to stop a TV program identifying a ward of court, but which was not about the care of the ward. The first instance court had granted an injunction in relation to a television programme dealing with the arrest and the conviction of a paedophile who was the father of … Continue reading R (Mrs) v Central Independent Television Plc: CA 17 Feb 1994
Administrative Discretion to be Used Reasonably The applicant challenged the manner of decision making as to the conditions which had been attached to its licence to open the cinema on Sundays. It had not been allowed to admit children under 15 years of age. The statute provided no appeal procedure, and the applicant sought a … Continue reading Associated Provincial Picture Houses Ltd v Wednesbury Corporation: CA 10 Nov 1947
An order was sought to protect from publicity a child whose mother faced trial for the murder of his brother. The child was now in care. Held: The court must balance the need to protect the child with the need for freedom of the press. The issue in the case was not itself about the … Continue reading In re S (A Child) (Identification: Restrictions on Publication): CA 10 Jul 2003
The complainant made a number of requests under the Freedom of Information Act 2000 (the Act) to HM Treasury (the Treasury) for information surrounding the consultation paper Restriction of pensions tax relief: a discussion document on the alternative approach dated July 2010. The requests which have been considered by the Commissioner within this Notice were … Continue reading HM Treasury (Decision Notice): ICO 5 Sep 2011
Charitable Company- Directors’ Status and Duties A married couple set up a charitable foundation to assist children in developing countries. When the marriage failed an attempt was made to establish a second foundation with funds from the first, as part of W leaving the Trust. Court approval was obtained, but the court ordered the remaining … Continue reading Lehtimaki and Others v Cooper: SC 29 Jul 2020
The complainant made a number of requests for various pieces of information relating to the Towry Law takeover of Edward Jones. The Commissioner’s decision is that some of the requested information is not held, that the Financial Services Authority was correct to withhold some of the information under section 43(2) and section 44(1)(a) of the … Continue reading Financial Services Authority (Decision Notice): ICO 29 Sep 2011
Dismissed Citations:  UKFTT 2017 – 0211 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 24 April 2022; Ref: scu.618438
Presumption of Damage in Defamation is rebuttable The defendant complained that the presumption in English law that the victim of a libel had suffered damage was incompatible with his right to a fair trial. They said the statements complained of were repetitions of statements made by US authorities. The claimant had asserted that no more … Continue reading Dow Jones and Co Inc v Jameel: CA 3 Feb 2005
Allowed Citations:  UKFTT 2017 – 0102 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 01 April 2022; Ref: scu.598417
Dismissed Citations:  UKFTT 2017 – 0118 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 01 April 2022; Ref: scu.598415
Dismissed Citations:  UKFTT 2017 – 0018 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 01 April 2022; Ref: scu.598414
Dismissed Citations:  UKFTT 2016 – 0315 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 01 April 2022; Ref: scu.598411
The complainant requested information from the public authority relating to complaints and correspondence about websites he was involved with. The public authority refused to deal with the request on the grounds that it was vexatious, citing section 14(1) of the Freedom of Information Act 2000. The Commissioner finds that the public authority failed to provide … Continue reading New Milton Town Council (Decision Notice): ICO 22 Aug 2011
Citations:  UKFTT 2011 – 0084 (GRC) Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 27 March 2022; Ref: scu.464749
Citations:  UKFTT EA – 2011 – 0288 Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 06 February 2022; Ref: scu.578447
Dismissed Citations:  UKFTT EA – 2012 – 0084 Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 06 February 2022; Ref: scu.578453
Citations:  UKFTT EA – 2012 – 0119 Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 06 February 2022; Ref: scu.578486
Citations:  UKFTT EA – 2012 – 0115 Links: Bailii Statutes: Freedom of Information Act 2000 Jurisdiction: England and Wales Information Updated: 06 February 2022; Ref: scu.578483
The complainant requested copies of the legal advice sought by the Department for Communities and Local Government relating to the issue of whether Energy Performance Certificates for private dwellings contain personal data according to the definition in the Data Protection Act 1998. DCLG withheld the legal advice using section 42(1) of the Freedom of Information … Continue reading Department for Communities and Local Government (Decision Notice): ICO 13 Sep 2011
Dismissed  UKFTT 2015 – 0296 (GRC) Bailii Freedom of Information Act 2000 England and Wales Information Updated: 27 January 2022; Ref: scu.572784
Dismissed  UKFTT 2015 – 0095 (GRC) Bailii Freedom of Information Act 2000 England and Wales Information Updated: 12 January 2022; Ref: scu.561384
The claimant sought judicial review of a decision to search him whilst travelling to a public protest in London. A previous demonstration involving this group had resulted in criminal damage, but neither the claimant nor his companions were found to be in possession of any materials for causing damage. The claimant said that the officer … Continue reading Howarth v Commissioner of Police of The Metropolis: QBD 3 Nov 2011
The defendant published a film showing the claimant involved in sex acts with prostitutes. It characterised them as ‘Nazi’ style. He was the son of a fascist leader, and a chairman of an international sporting body. He denied any nazi element, and claimed in breach of confidence. Held: ‘The law [of confidence] now affords protection … Continue reading Mosley v News Group Newspapers Ltd: QBD 24 Jul 2008
ICO The complainant made a freedom of information request to NHS England for the costs of suspending a named doctor. In response NHS England refused to confirm or deny if the requested information was held under section 40(5)(b)(i). The Commissioner’s decision is that section 40(5)(b)(i) was incorrectly applied and NHS England failed to comply with … Continue reading NHS Commissioning Board (NHS England) (Health (NHS)): ICO 28 Jan 2016
Each appellant complained of the disclosure by the respondent of very old and minor offences to potential employers, destroying prospects of finding work. Two statutory schemes were challenged, raising two separate questions, namely whether any interference with Article 8 ECHR is: (1) ‘in accordance with the law’ (‘the legality test’) and (2) ‘necessary in a … Continue reading Gallagher for Judicial Review (NI): SC 30 Jan 2019
The claimants had been stopped by the police using powers in the 2000 Act. They were going to a demonstration outside an arms convention. There was no reason given for any suspicion that the searches were needed. Held: The powers given to the police were too wide, provided inadequate protection against abuse, and violated the … Continue reading Gillan and Quinton v The United Kingdom: ECHR 12 Jan 2010
The Attorney General appealed against a decision for the release under the Act and Regulations of letters from HRH The Prince of Wales to various ministers and government departments. Held: The appeal failed (Majority). The A-G had not been free to rely upon section 53 to issue a certificate avoiding the requirement to disclose the … Continue reading Evans and Another, Regina (on The Application of) v Attorney General: SC 26 Mar 2015
A prison policy requiring prisoners not to be present when their property was searched and their mail was examined was unlawful. The policy had been introduced after failures in search procedures where officers had been intimidated by the presence of prisoners. Particularly when examining documents subject to legal professional privilege, the rules did not allow … Continue reading Regina (Daly) v Secretary of State for the Home Department: HL 23 May 2001
The appellant had been ostentatiously photographed by the police as he left a company general meeting. He was a peaceful and lawful objector to the Arms Trade. He appealed against refusal of an order for the records to be destroyed. The police had refused to disclose elements of their policies for overt photography. Held: The … Continue reading Wood v Commissioner of Police for the Metropolis: CA 21 May 2009
The bank challenged measures taken by HM Treasury to restrict access to the United Kingdom’s financial markets by a major Iranian commercial bank, Bank Mellat, on the account of its alleged connection with Iran’s nuclear weapons and ballistic missile programmes. The bank sought to have the direction given under section 7 of the 2008 Act. … Continue reading Bank Mellat v Her Majesty’s Treasury (No 2): SC 19 Jun 2013
The complainant requested information held by the ICO in relation to various trade union groups. The ICO confirmed that it held the relevant information but refused to provide it on the grounds that it was exempt from disclosure under section 44(1)(a) of the Freedom of Information Act 2000 by virtue of section 59(1) of the … Continue reading Information Commissioner (Decision Notice): ICO 17 Jan 2011
The complainant made a request to Royal Mail Group PLC under the Freedom of Information Act 2000 for information regarding how much undeliverable mail was sent for disposal by the National Returns Centre in each financial year from 2004/2005 to 2009/2010. The Royal Mail confirmed that it held part of the requested information but stated … Continue reading Royal Mail (Decision Notice): ICO 6 Jan 2011
ICO The complainant asked the Department of Health (DOH) to provide: ‘electronic copies of the ranked hospital level data for Rounds 5, 6 and 7 of the National Sentinel Stroke Audit as published to date, both the organisational and clinical components. Note that these requests are not for the data in the published Public Reports … Continue reading Department of Health (Decision Notice): ICO 7 Dec 2011
The complainant requested under the Freedom of Information Act 2000 (the ‘Act’) some information about a compliance investigation that the MHRA had undertaken. The MHRA replied that it believed that section 44 applied and it withheld the information. It also withheld the name of one of its member’s of staff by virtue of section 40(2). … Continue reading Medicines and Healthcare Products Regulatory Agency (Decision Notice) FS50384738: ICO 22 Aug 2011
ICO The complainant requested the geographical equivalent number(s) behind a 0845 number under the Freedom of Information Act 2000. The public authority confirmed that it held the information, but that it would not provide it because it felt that section 36(2)(c) [disclosure would prejudice the effective conduct of public affairs] applied to the information. It … Continue reading Department for Work and Pensions (Decision Notice): ICO 23 Aug 2011
ICO The complainant requested information relating to the absence of a senior member of the council’s staff. The council said that some information was already publicly available and that it wished to rely on section 40(2) of the Freedom of Information Act 2000, the exemption relating to third party personal data. During the Commissioner’s investigation, … Continue reading Wirral Metropolitan Borough Council (Decision Notice): ICO 30 Apr 2013
Claims of infringement were made as to copyright works being various works about Scientology. Extracts had appeared in the defendant’s book which was critical of the cult. It was submitted by the plaintiff that the fair dealing section applied only to criticism of the work, not of the doctrine or philosophy underlying it. Held: The … Continue reading Hubbard v Vosper: CA 1971
ICO The complainant has requested information about NHS South West’s contract with a named company. NHS South West provided the complainant with some of the requested information but withheld some information under section 42 and section 43(2) FOIA. NHS South West became defunct on 1 April 2013. The Department of Health Legacy Management Team has … Continue reading Department of Health (Decision Notice): ICO 30 Jul 2013
ICO The complainant asked Greater Manchester Police (the ‘public authority’) to provide information relating to interpreters. The public authority refused to deal with the request on the grounds that it was vexatious, citing section 14(1) of the Freedom of Information Act 2000. The Commissioner finds that the public authority failed to provide adequate reasons that … Continue reading Greater Manchester Police (Decision Notice): ICO 15 Sep 2011
 UKFTT EA – 2013 – 0211 (GRC Bailii Freedom of Information Act 2000 Information Updated: 01 December 2021; Ref: scu.522684
 UKFTT EA – 2012 – 0125 (GRC Bailii Freedom of Information Act 2000 England and Wales Information Updated: 26 November 2021; Ref: scu.517842
 UKFTT EA – 2012 – 0184 (GRC Bailii Freedom of Information Act 2000 England and Wales Information Updated: 26 November 2021; Ref: scu.517833
The claimants said that an order that they deliver up documents leaked to them regarding a possible takeover violated their right to freedom of expression. They complained that such disclosure might lead to the identification of journalistic sources. Held: The protection of journalistic sources was part of the protection of freedom of expression: ‘protection of … Continue reading Financial Times Ltd and Others v The United Kingdom: ECHR 15 Dec 2009
The claimant had supported the grant of a visa to a woman in order to speak to members of Parliament who was de facto leader of an Iranian organsation which had in the past supported terrorism and had been proscribed in the UK, but that proscription had been cancelled by the Tribunal. Lord Carlile appealed … Continue reading Lord Carlile of Berriew QC, and Others, Regina (on The Application of) v Secretary of State for The Home Department: SC 12 Nov 2014
The appellant had been unsuccessful in litigation against his former bank. The Financial Services Authority had subsequently investigated his complaint against the bank. Using section 7 of the Data Protection Act 1998, he requested disclosure of his personal data held by the bank. The Financial Services Authority disclosed some copies of documents relating to the … Continue reading Durant v Financial Services Authority: CA 8 Dec 2003
The claimant appealed against the denial of her claim that the defendant had infringed her right to respect for her private life. She was a model who had proclaimed publicly that she did not take drugs, but the defendant had published a story showing a picture of her leaving a drug addiction clinic, along with … Continue reading Campbell v Mirror Group Newspapers Ltd (MGN) (No 1): HL 6 May 2004
Fair Coment on Political Activities The defendant newspaper had published articles wrongly accusing the claimant, the former Prime Minister of Ireland of duplicity. The paper now appealed, saying that it should have had available to it a defence of qualified privilege because of the claimant’s status as a politician. Held: The appeal failed (Lords Hope … Continue reading Reynolds v Times Newspapers Ltd and others: HL 28 Oct 1999
False Imprisonment Damages / Immigration Detention The respondent had held the claimant in custody, but had failed to follow its own procedures. The claimant appealed against the rejection of his claim of false imprisonment. He had overstayed his immigration leave, and after convictions had served a prison sentence. When about to be released, an order … Continue reading Kambadzi (previously referred to as SK (Zimbabwe)) v Secretary of State for The Home Department: SC 25 May 2011
Applicants had sought disclosure of information supplied by members of Parliament in support of expenses claims. The Office appealed against an order from the Commissioner to produce that information, saying that the actions of Parliament are not subject to judicial control or review. Held: The appeal was dismissed. The tribunal had made no error of … Continue reading Corporate Officer of the House of Commons v The Information Commissioner and others: Admn 16 May 2008
(Southwark Crown Court) The defendants faced charges of false accounting in connection with expense claims as members of parliament, three of the House of Commons and one of the Lords. Each claimed that the matter was covered by Parliamentary Privilege and that a civil court had no jurisdiction to try them. Held: The claims to … Continue reading Regina v Morley; Regina v Chaytor; Regina v Devine; Regina v Lord Hanningfield: CC 11 Jun 2010
The applicant publisher said that the finding against it of breach of confidence and the system of success fees infringed it Article 10 rights to freedom of speech. It had published an article about a model’s attendance at Narcotics anonymous meetings. Held: The finding of a breach of confidence against the applicant amounted to an … Continue reading MGN Limited v United Kingdom: ECHR 18 Jan 2011
The defendant had published a story in its newspaper. At that time it attracted Reynolds qualified privilege. After the circumstances changed, the paper offered an updating item. That offer was rejected as inadequate. Held: The qualified privilege was attracted at the time of the original publication. Striking the appropriate balance, this was a story of … Continue reading Flood v Times Newspapers Ltd: QBD 2 Oct 2009
The claimants had been detained under the 1971 Act, after completing sentences of imprisonment pending their return to their home countries under deportations recommended by the judges at trial, or chosen by the respondent. They challenged as unlawful the respondent’s, at first unpublished, policy introduced in 2006, that by default, those awaiting deportation should be … Continue reading Lumba (WL) v Secretary of State for The Home Department: SC 23 Mar 2011
Police Retention of Suspects DNA and Fingerprints The claimants complained that their fingerprints and DNA records taken on arrest had been retained after discharge before trial, saying the retention of the samples infringed their right to private life. Held: The parts of DNA used for testing are not generally capable of revealing medical information about … Continue reading S, Regina (on Application of) v South Yorkshire Police; Regina v Chief Constable of Yorkshire Police ex parte Marper: HL 22 Jul 2004
An MP had asked the Agency under the 2002 Act for details of all incidents of childhood leukaemia for both sexes by year from 1990 to 2003 for all the DG (Dumfries and Galloway) postal area by census ward. The Agency replied by saying that the release of the information would put at risk the … Continue reading Common Services Agency v Scottish Information Commissioner: HL 9 Jul 2008
Defamation of Labour MP by Unite and Blogger The claimant now a former MP had alleged that a posting on a website supported by the first defendant was false and defamatory. The posting suggested that the claimant had acted dishonestly in applying online for a category of membership of the union. The defendants pursued defences … Continue reading Turley v Unite The Union and Another: QBD 19 Dec 2019
The applicants had been imprisoned and held without trial, being suspected of international terrorism. No criminal charges were intended to be brought. They were foreigners and free to return home if they wished, but feared for their lives if they did. A British subject, who was suspected in the exact same way, and there were … Continue reading A v Secretary of State for the Home Department, and X v Secretary of State for the Home Department: HL 16 Dec 2004
(New Zealand) The plaintiff, an MP, pursued a defamation case. The defendant wished to argue for the truth of what was said, and sought to base his argument on things said in Parliament. The plaintiff responded that this would be a breach of Parliamentary privilege. Held: A Defendant may not use libel proceedings to impugn … Continue reading Prebble v Television New Zealand Ltd: PC 27 Jun 1994
A newspaper company appealed against an order preventing it naming a footballer who, they claimed, had been unfaithful to his wife. Held: There remains a distinction between the right of privacy which attaches to sexual activities within and outside a marriage. An order restricting the freedom of the press requires positive and clear justification. The … Continue reading A v B plc and Another (Flitcroft v MGN Ltd): CA 11 Mar 2002
The plaintiff suffered catastrophic brain damage as a result of cardiac arrest induced by respiratory failure as a child whilst at the defendant hospital. A doctor was summoned but failed to attend, and the child suffered cardiac arrest and brain damage. Held: In cases of diagnosis and treatment there are cases where, despite a body … Continue reading Bolitho v City and Hackney Health Authority: HL 24 Jul 1997
The defendants considered publication of alleged financial irregularities by the claimant, who sought to restrain publication. The defendants argued that under the Act, prior restraint should not be used unless a later court would be likely to restrict publication. The court below held the test is not that of the balance of probabilities but rather … Continue reading Cream Holdings Limited and others v Banerjee and The Liverpool Daily Post and Echo Limited: CA 13 Feb 2003
Right to be Forgotten is not absolute The two claimants separately had criminal convictions from years before. They objected to the defendant indexing third party web pages which included personal data in the form of information about those convictions, which were now spent. The claims were in Data Protection and the common law tort of … Continue reading NT 1 and NT 2 v Google Llc: QBD 13 Apr 2018
Arrested Person must be told basis of the Arrest Police officers appealed against a finding of false imprisonment. The plaintiff had been arrested under the 1921 Act, but this provided no power of arrest (which the appellant knew). The officers might lawfully have arrested the plaintiff for the felony of stealing a bale of cloth, … Continue reading Christie v Leachinsky: HL 25 Mar 1947
The claimants had been employed by a local authority and then transferred to the respondents. They had had the benefit that their terms of employment were subject to collective agreement. The respondent was not part of the negotiation of later . .
The complainant requested information from Medway Council relating to a property valuation. After initially denying that it held relevant information, the council provided the information that it held following the Commissioner’s intervention. The . .
The complainant requested from the Adjudicator’s Office a number of items of information regarding the process of ex gratia payments and underpinning methodology. He was unhappy with one aspect of the response where the public authority claimed that . .
The claimant had sought his personal data as to a communication between the defendant and the coroner holding the inquest into the claimant’s wife’s death. . .
The claimant pursued Employment Tribunal proceedings against the Immigration Service when his security clearance was withdrawn. The Tribunal allowed the respondent to use a closed material procedure under which it was provided with evidence unseen . .
PC (Anguilla) A first non-religious radio station had been formed, but came to include much criticism of the government. One programme was suspended by the government. The programme makers complained that this . .
The Association challenged the imposition of minimum pricing systems for alcohol, saying that it was in breach of European law. After a reference to the ECJ, the Court now considered its legality.
Held: The Association’s appeal failed. Minimum . .
The mother of the child on behalf of whom the application was made, was to face trial for murder. The child was in care and an order was sought to restrain publiction of material which might reveal his identity, including matters arising during the . .
The complainant requested for access to all the documents held by the Information Commissioner’s Office in connection with its investigation of two Freedom of Information complaints. The ICO refused to disclose the requested information citing . .
Inhibition of free and frank provision of advice s 36(2)(b)(i) . .
FOIA S.50 Decision notice by Commissioner, appeal under section 57. . .
(Scotland) The appellant had variously been convicted in reliance on evidence gathered at different stages before arrest, but in each case without being informed of any right to see a solicitor. The court was asked, as a devolution issue, at what . .
The plaintiffs, who were London merchants, had been asked by Egyptian buyers to supply ‘feveroles’. Not knowing what this term meant, they asked the defendants’ representative, who responded that ‘feveroles’ meant horsebeans. Relying on this . .
Part Allowed . .
The two prisoners, serving life sentences for murder, had had their appeals rejected. They continued to protest innocence, and sought to bring their campaigns to public attention through the press, having oral interviews with journalists without . .
The defendant had requested the Isle of Man authorities to investigate the part if any taken by the plaintiff in a major fraud. No charges were brought against the plaintiff, but the documents showing suspicion came to be disclosed in the later . .
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