A Multi-Jurisidctional Comparison of the Concept of 'Information' and 'Public Bodies' in Freedom of Information Statutes

Abstract

Freedom of information (FOI) is recognised in various international and regional human rights covenants as well as national laws in numerous countries. In the context of Malaysia, to date there is no FOI legislation at the federal level but the State Legislative Assemblies of Selangor and Penang have enacted their respective FOI enactments. This article aims to compare the scope of application of FOI laws in defining information and public bodies in Selangor and Penang with legislations in other jurisdictions such as the United Kingdom, India and South Africa.

Keywords: freedom of information, scope of information, scope of public bodies