The complainant alleged that the Department of Justice Canada (Justice) improperly withheld information under section 23 (legal advice and litigation privilege) of the Access to Information Act in response to an access request for legal fees related to a specific litigation file. Justice claimed solicitor-client privilege to disbursements and details of expenses included in a cost-recovery report. While the Information Commissioner agreed that disbursements are subject to a presumption of privilege, her investigation determined that the presumption was rebutted as there was no reasonable possibility that an assiduous inquirer could use the information at issue to deduce or otherwise acquire communications protected by the privilege. The Commissioner therefore recommended that Justice disclose all information initially withheld pursuant to section 23 of the Act. Justice gave notice that the recommendation would be implemented. The complaint is well founded.