Section 35(2) is not irrelevant, simply because he can use the SAR route, and should at least be considered since it has been raised.
However I agree that in practice this would be a likely refusal under s35(2) as you are not really able to judge necessity - and as has been pointed out at some stage the CPR can be used and the court can consider disclosure of documents.
So I would probably decline under s35(2), grab a £10 bonus, and deal with it as an SAR applying s7(4) and any exemptions, such as s29 and possibly 30, as appropriate, bearing in mind that confidentiality is only a relevant issue where TP data involved, and not necessarily decsisive
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