It is clear from the provisions of Section 14(1) of FIA that the right of access to information in custody of a public official, agency or institution is not an unbridled, uncontrolled and absolute right. It is curtailed by Section 14(1) of the Act by denying access to private or personal information of a citizen in custody of a public official. For any citizen to have access to personal information in custody of a public official or institution, he must show that: (1) The individual to whom the information relates has given his consent to the disclosure or (2) That the information is publicly available anyway or (3) That the disclosure is in the public interest and the public interest outweighs the protection of the privacy of the individual to whom the information relates.
— M.O. Bolaji-Yusuff, JCA. CCB v Nwankwo (2018) – CA/E/141/2017