The National Maternity Hospital in Holles Street, Dublin has been accused by the Information Commissioner of "obstructing" her investigations.
Last year Emily O'Reilly complained about Holles Street's "short-sighted" decision to destroy all its pre-1968 medical records.
The decision hindered inquiries by the Dunne postmortem inquiry into the practice of hospitals selling baby body parts to international pharmaceutical companies.
Yesterday, Ms O'Reilly pointedly went further by saying the hospital's co-operation with her office fell "well short of the standard of reasonableness" necessary. "I would go so far as to say that the behaviour of the hospital in this case amounted to obstruction of my office in the performance of its functions," she declared, in one of the strongest-ever criticisms of an institution.
Holles Street, she said, had been guilty of an "unwarranted delay" in supplying records requested by her office and had tried to set down preconditions before they would co-operate at all.
Accusing the hospital of "an adversarial and confrontational approach", she said it must have incurred "substantial and mostly unnecessary legal costs" which will have to be paid by the taxpayer. Throughout the affair, requests for information from her staff were dealt with by the hospital's solicitors, rather than by a Freedom of Information officer, as should be normal.
Ms O'Reilly also reported that requests under the Freedom of Information (FOI) Act, which was restricted by the Government, continued to fall.
In 2004, 12,597 requests were made: a drop of 32 per cent on 2003 and a fall of 27 per cent of the numbers received by Government departments and State agencies during 2002. The cost of an FOI request should fall, she once again recommended, though the Government has so far completely ignored her calls, and the calls of others, for change.
"I do not believe that the Oireachtas could have anticipated so great a decline in usage of the Act when amending the Act and approving the scale of fees to be charged," she said.
The Republic of Ireland is the only one of the eight examined which charges the public to have a refusal decision re-examined, and which charges for an appeal to the Information Commissioner.
While the Government has restricted the FOI Act, Eastern European countries have adopted a radically different approach: "They view FOI as both a cornerstone and a hallmark of their new democracies, alongside ethics legislation and the introduction of the Ombudsman system.
"Some countries have introduced extremely liberal legislation, at the same time, ironically, as many countries in 'Old Europe' are restricting theirs for various domestic or international reasons," said Ms O'Reilly.
Emphasising the value of the FOI Act, she said: "The recently published Travers report on the practice of charging for long-term nursing care, highlighted once again the need for transparency and accountability within the public administration system."
Dan Boyle TD, of the Green Party, said the fall in FOI requests proved the Government had "now successfully decommissioned" the legislation and was addicted "to spin and secrecy".
