A document prepared for multiple purposes may qualify for Cabinet document exemption under s.28(1)(b) or (ba) of the Freedom of Information Act 1982 (Vic) if a substantial purpose of its preparation was submission to Cabinet or briefing a Minister on Cabinet issues. The purpose need not be the sole purpose, but must be causative — in the sense that but for its presence the document would not have been prepared. Tribunals must make express findings on the purpose of preparation and weigh the significance of competing purposes.
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