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‘Freedom of information’ legislation, establishing a public right of access to most government records, is an international trend. With the exception of the Swedish constitutional provision, most of these laws have been adopted since the 1960s. They go beyond merely reforming the criminal law on government information by establishing a positive right of access to records, with narrowly‐drawn exemptions, and with independent arbiters to decide disputes. Three Commonwealth countries with Westminster‐style constitutions have adopted such laws, and it seems likely that the UK will follow by 1990.

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