Judgment_paragraph 32 · International Management Group v European Commission (T-110/15)

32The case-law referred to in paragraph 29 above underlines the fact that the ratio legis behind the application of such general presumptions is connected with the overriding need to ensure the proper operation of the procedures in question and to ensure that their objectives are not undermined. Accordingly, a general presumption may be recognised on the basis that access to the documents involved in certain procedures is incompatible with the proper conduct of those procedures and that the risk that those procedures could be undermined, on the understanding that general presumptions ensure that the integrity of the conduct of the procedure can be preserved by limiting intervention by third parties (see, to that effect, judgment of 25 September 2014 in Spirlea v Commission, T‑306/12, under appeal, EU:T:2014:816, paragraphs 57 and 58, and Opinion of Advocate General Wathelet in Joined Cases LPN and Finland v Commission, C‑514/11 P and C‑605/11 P, EU:C:2013:528, points 66, 68, 74 and 76). The application of specific rules provided for by a legal measure relating to a procedure conducted before an EU institution for the purposes of which the documents requested were produced is one of the criteria for recognising a general presumption (see, to that effect, judgment of 11 June 2015 in McCullough v Cedefop, T‑496/13, not published, EU:T:2015:374, paragraph 91 and the case-law cited, and Opinion of Advocate General Cruz Villalón in Council v Access Info Europe, C‑280/11 P, EU:C:2013:325, point 75).