Our Ref: FOI-2025/0912144629
2 October 2025
Dezmond Lukas
By email:
xxxxxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxx.xxx.xx
Dear Dezmond Lukas,
Request for documents under the Freedom of Information Act 1982 (Cth)
I refer to your request under the
Freedom of Information Act 1982 (Cth) (FOI Act)
received by the Australian Human Rights Commission (Commission) on 12 September
2025 for:
[C]opies of actual or proposed United Nations submissions you were carbon copied or given
a copy by private organisations, not for profit organisations, charities or the public in the last
5 years.
United Nations submissions include formal documents like resolutions, decisions, and
reports, along with individual complaints and activity reports, and various written
contributions for consultations. These submissions come from different actors, including
Member States, UN bodies, NGOs, and individuals, and are submitted through specific online
platforms like gDoc or dedicated forms.
United Nations (UN) cal s for input typical y come in the form of cal s for written submissions
from governments, civil society organizations, academics, and other stakeholders, often for
specific reports, thematic studies, or the mandate of a UN Special Rapporteur. These cal s
seek detailed information, evidence-based recommendations, and examples of good
practices on human rights issues, ranging from specific topics like torture and counter-
terrorism to broader initiatives like the Sustainable Development Goals. Submissions usual y
have specific deadlines, word limits, and are sent to designated UN addresses or entities
I am an officer authorised under section 23(1) of the FOI Act to make decisions in
relation to FOI requests.
I am writing to tel you that I believe that the work involved in processing the request in
its current form would substantially and unreasonably divert the resources of the
Commission from its other operations due to the scope of the request. This is called a
‘practical refusal reason’ (s 24AA FOI Act).
Australian Human Rights
GPO Box 5218
General enquiries
1300 369 711
Commission
Sydney NSW 2001
National Info Service
1300 656 419
ABN 47 996 232 602
www.humanrights.gov.au
TTY
1800 620 241
Australian Human Rights Commission
On this basis, I intend to refuse access to the documents in the request set out below.
However, before I make a final decision to do this, you have an opportunity to revise
the request. This is cal ed a ‘request consultation process’ as set out under section
24AB of the FOI Act. You have 14 days to respond to this notice in one of the ways set
out below.
Why I intend to refuse the request
On 12 September 2025, the Commission acknowledged receipt of your FOI request.
On 17 September 2025, I emailed you to consider reducing the scope of your request,
as my preliminary assessment indicated there may be a practical refusal reason under
s 24AA(1)(a)(i) of the FOI Act. I wrote:
Could you please consider how to reduce the scope of the request, for example:
-
Limiting it to a particular submission or set of submissions
-
Limiting it to a particular named organisation
-
By providing a set of search terms for our IT department to use to retrieve specific
documents you wish to obtain copies of
Otherwise, the resource impact of searching every Commission email for when we may have
been cc:ed or sent a copy of UN submissions in the last 5 years would be substantial and
unreasonable.
I have not received a response to that email.
I consider that a practical refusal reason exists in relation to the request because the
time and work involved in processing the request in its current form would
substantial y and unreasonably divert the resources of the Commission from its other
operations. This is because of:
• the volume of material likely to be captured by a search for ‘UN submissions’,
and
• the time required to review the results of this search to identify documents
relevant to your request.
For any email identified as responsive to your request, the Commission would likely
also need to consult with the third party or parties who provided or cc:ed us in the
submission, in accordance with ss 27 and 27A.
I consider that the work involved would substantially and unreasonably divert the
resources of the Commission from its other operations due to the scope of the
request. This is a practical refusal reason under s 24AA(1)(a)(i) of the FOI Act.
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Australian Human Rights Commission
Request consultation process
You now have an opportunity to revise your request to enable it to proceed.
Revising your request can mean narrowing the scope of the request to make it more
manageable or explaining in more detail the specific documents you wish to access.
For example, by providing more specific information about exactly what documents
you are interested in, the Commission wil be able to pinpoint the documents more
quickly and avoid using excessive resources to process documents you are not
interested in.
Before the end of the consultation period, you must do one of the following, in writing:
• withdraw your request
• make a revised request
• tel us that you do not wish to revise your request.
The consultation period runs for 14 days and starts on the day after you are
given this notice.
If you revise the request in a way that adequately addresses the practical refusal
grounds outlined above, we wil recommence processing it. Please note that the time
taken to consult you regarding the scope of the request is not taken into account for
the purposes of the 30-day time limit for processing the request. This means that the
statutory deadline by which the Commission is required to make a decision on your
request may be extended past
13 October 2024.
If you do not do one of the three things listed above during the consultation period or
you do not consult the contact person during this period, the request wil be taken to
have been withdrawn.
Contact officer
If you would like to revise your request or have any questions, please contact me using
the below contact information.
Yours sincerely,
Lara Renton
Acting General Counsel
T +61 2 9284 9865
E xxxx.xxxxxx@xxxxxxxxxxx.xxx.xx
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Document Outline
