First-of-its-kind case on parents’ rights to information on sex education lessons

22 Sep 2025

The Upper Tribunal (Administrative Appeals Chamber) has handed down judgment in a freedom of information appeal brought by Clare Page, a mother who wished to obtain teaching materials used by a charity (School of Sexuality Education) for a sex education session at her daughter’s school, as well as the names of the individuals who delivered the session.

Ms Page’s request was refused by the school, including on the basis that disclosing the materials would constitute a breach of confidence. This decision was subsequently upheld by both the Information Commissioner and, on appeal, the First-tier Tribunal.

The Upper Tribunal has dismissed Ms Page’s further appeal. Amongst other matters, the judgment concludes that section 405 of the Education 1996 – which allows parents to withdraw their children from sex education in state schools – contains an implied obligation to provide information about what will be taught, but does not require a school to provide all materials that will be used.

The judgment is available here.

Will Perry successfully acted for the Information Commissioner.

The case has previously been reported in the Daily Mail, Times and Telegraph.

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