4.3.7.3. Operations of public bodies Section 44 of PAIA gives Information Officers the ability to refuse access to a record if it will hamper the operations of a public body. Section 44 is broad, a number of records listed under operations include:  Minutes of meetings;  Records containing advice or opinions;  Records pertaining to consultations with other bodies;  Records pertaining to the formulation of policies or recommendations. The courts have provided further direction on how the section 44 should be applied: Minister of Local and Provincial Government v Unrecognised Traditional Leaders Limpopo Province Sekhukhuneland The court held that provisions that limit access to information must be interpreted in light of the Constitution. The court applied the purposive approach to interpret section 44(1)(a), meaning that if a record is not held for purposes of formulating polices then such a record should be disclosed. President of the Republic of South Africa and Others v the M&G Media Limited Constitutional Court shared the same principles as in the case above and stated that if the record requested was not for the formulation of policy the record should be released as such release will not hamper the operations of the public body. The court further held that a public body must demonstrate that the report was originally intended for formulation of policy. South African Human Rights Commission 54