The question whether raw data collected by public departments or officials constitutes a public record, within the meaning of the rule giving private persons the right of access to, inspection of, or copying of public records, appears to depend largely on

The question whether raw data collected by public departments or officials constitutes a public record, within the meaning of the rule giving private persons the right of access to, inspection of, or copying of public records, appears to depend largely on the provisions of the statute giving the right of access, inspection, or copying. Some cases take the view that material gathered by way of preliminary investigation does not become a public record before some official action of approval or disapproval. On the other hand, the drawing of a distinction between writings representing tentative action and those memorializing ultimate action has been regarded as objectionable, not only because it is inconsistent with the principle which underlies the statutes making public writings freely available for inspection, but also because it provides a device by which a public official can hinder a citizen's legitimate attempt to obtain writings which are clearly within the strictest definition of a public record.