Take-Aways (AI)
  • Fede­ral Court rejec­ted can­to­nal com­plaint and ruled that the Zurich Health Direc­to­ra­te must deci­de on access to GDK docu­ments, but did not inter­ve­ne in the com­plaint due to lack of legitimacy.
  • Court found that the prin­ci­ple of public access under IDG/ZH applies regard­less of the ori­gin of the docu­ments, but ori­gin remains rele­vant when weig­hing up interests.

The Zurich Health Direc­to­ra­te will have to deci­de anew on the inspec­tion of docu­ments of the Con­fe­rence of Can­to­nal Health Direc­tors (GDK). The appeal filed against this by the can­ton, which war­ned of a “breach of the dam”, was rejec­ted by the Fede­ral Supre­me Court in a judgment of 1C_370/2020 from June 14, 2021.

The Health Direc­to­ra­te had alre­a­dy rejec­ted the request of the asso­cia­ti­on Öffentlichkeitsgesetz.ch in the fall of 2018. The sub­ject mat­ter was invi­ta­ti­ons and Agen­da lists of board mee­tings of the GDK. The asso­cia­ti­on suc­cessful­ly appea­led the equal­ly nega­ti­ve appeal decis­i­on to the Zurich Admi­ni­stra­ti­ve Court. On May 14, 2020, the court refer­red the mat­ter back to the direc­to­ra­te for addi­tio­nal cla­ri­fi­ca­ti­on and a new decis­i­on (ruling VB.2020.00112).

Mate­ri­al­ly, the appli­cant had invo­ked the Zurich Law on Infor­ma­ti­on and Data Pro­tec­tion (IDG/ZH). Accor­ding to this, offi­ci­al docu­ments are basi­cal­ly acce­s­si­ble (§ 20, para. 1), unless ano­ther pro­vi­si­on or over­ri­ding inte­rests con­flict with this (§ 23, para. 1). The Health Direc­to­ra­te, on the other hand, took the posi­ti­on that one could not “on the detour via a sin­gle can­ton” could inspect docu­ments of inter­can­to­nal bodies (VGer ZH, E. 2.3.3 a.E.). Befo­re the Fede­ral Supre­me Court, it accor­din­gly clai­med that

the Can­ton of Zurich had never issued docu­ments of an inter­can­to­nal orga­nizati­on based on the prin­ci­ple of public access. Such a decis­i­on would have a Dam break effect, espe­ci­al­ly sin­ce it would intro­du­ce the prin­ci­ple of publi­ci­ty for inter­can­to­nal insti­tu­ti­ons and thus have a gene­ral impact on the publi­ci­ty of inter­can­to­nal insti­tu­ti­ons” (BGer, E. 2.3).

The Fede­ral Supre­me Court denied right from the start the Right of appeal of the com­mu­ni­ty (E. 1), becau­se the lower court had pre­vious­ly “only deci­ded that the Health Direc­to­ra­te was respon­si­ble for the” (E. 2.4). Obiter, it nevert­hel­ess took the liber­ty of poin­ting out that the ori­gin of the docu­ments was not decisi­ve for the vali­di­ty of the prin­ci­ple of publicity:

Rather, accor­ding to Sec­tion 20 (1) IDG/ZH, every per­son has the right to access infor­ma­ti­on held by a public body, ‘[…] irre­spec­ti­ve of its form of pre­sen­ta­ti­on and infor­ma­ti­on car­ri­er’ (Sec­tion 3 (2) IDG/ZH).” (E. 2.4)

At the same time it cla­ri­fi­ed that the­se addres­see-cen­te­red view no exten­si­on of the prin­ci­ple of public access to inter­can­to­nal insti­tu­ti­ons (E. 2.4). Also, the ori­gin of the docu­ments was after all “on the que­sti­on of gran­ting access and, in par­ti­cu­lar, on the balan­cing of inte­rests.” of signi­fi­can­ce (E. 2.5).

As a result, the Fede­ral Supre­me Court did not inter­ve­ne in the appeal of the can­ton for lack of legi­ti­ma­cy (E. 3) and recom­men­ded its­elf for the case that “the lower court final­ly grants the request for inspec­tion at issue in the pre­sent case.” (E. 2.5).