L1T FM Holdings UK Ltd, R (on the application of) & Anor v Secretary of State in the Cabinet Office

The Secretary of State's approach to open disclosure (presenting redacted documents as if complete) was inappropriate but ultimately remedied.

The original presentation risked misleading claimants. While the court approved the remedial steps taken, it clarified that future cases should utilize plain paper versions of documents with clear labeling of redactions and summaries.

The application to redact all civil servant names except those in the Senior Civil Service was refused.

The Secretary of State failed to provide specific national security reasons for redacting junior civil servant names beyond a general assertion.

The application to redact the names of GCHQ and NCA officers was granted.

The Secretary of State provided sufficient evidence demonstrating the risk to national security from disclosing these names.

No general requirement for marginal notes indicating redactions or summaries in open documents; however, such annotations are appropriate where they don't compromise national security.

Balancing the need to avoid misleading claimants with the protection of national security interests. A general endorsement on the document is often sufficient, marginal notes only needed in exceptional circumstances.