Century Club Is 'Public Authority' Under RTI Act, Land Grant By Mysuru Maharaja Amounts To 'Substantial Financing': Karnataka High Court

The Karnataka High Court has recently held that the Century Club, a prestigious members-only club situated in the centre of Bengaluru, is a 'Public Authority' under the Right to Information (RTI) Act. [2026 LiveLaw (Kar) 249]

The Division Bench of Justice Anu Sivaraman and Justice Venkatesh Naik T has dismissed the appeal filed by the Century Club, upholding the orders of a Single Judge and the Karnataka Information Commission in favour of transparent functioning of the club.

The court primarily reasoned that the Maharaja of Mysuru had earlier financed the institution of the club in the 7.5 acres of public land adjacent to Cubbon Park in 1913.

“…Admittedly, the Century Club is situated on the land measuring 7.5 acre and it was granted by the then Maharaja of Mysuru on 27.10.1913, free of cost, and therefore, it is a non-Government organisation substantially financed by the funds provided by the appropriate Government. The land on which the Century Club is situated belongs to the public and therefore, the Century Club cannot enrich themselves at the cost of the public money. Moreover, the Century Club is not paying any rent or lease or any royalty to the Government and the entire land of 7.5 acre is granted free of cost, which would amount to substantial finance by the Government and the property belongs to the State Government”, the court said.

Relying on Thalappalam Service Cooperative Bank Limited and Others v. State of Kerala & Ors. (2013), the court held that an entity receiving 'substantial financing' from the government directly or indirectly, would be considered a public authority for the purpose of RTI Act.

To recap, in 2012, RTI activist S. Umapathy sought certain information from the Club which was rejected on the ground that it isn't a 'Public Authority' under Section 2(h) of the RTI Act. Based on a subsequent complaint preferred by the activist before the Karnataka Information Commission, in 2017, the club was declared a 'Public Authority' which needs a 'Public information Officer' to pass on the information sought by the public. This order of the Commission was challenged before the single judge bench which got dismissed in July 2025. Aggrieved by the order, the Club filed a writ appeal before the Division Bench.

The arguments before the Division Bench revolved around whether the 7.5-acre premises granted by the erstwhile Mysuru Maharaja fell within the ambit of 'substantial financing by the government', which could bring the Club under the purview of RTI Act.

Before the High Court, Century Club submitted that the 7.5 acres was a personal grant made by the Maharaja, who was also the Patron-in Chief of the Club in 1913. The daily operations of the Club rely solely on membership fees and not on any form of government funding, it was submitted further. Moreover, the Club does not perform any public functions, the counsel added.

However, the court disagreed with such contentions levelled by the Club.

“…In relation to the land granted in question, no specific document has been placed on record to indicate that said land belonged personally to the Maharaja of Mysuru. The grant made in the name of Maharaja of Mysuru would also indicate that it is not the personal property of the Maharaja of Mysuru. If a King/a Ruler granted land free of cost before independence, the grant is generally recognised as an Act of the State or the sovereign rather than a strictly private transaction. Therefore, providing a major piece of land to the Century Club, that too, in the heart of the Metropolitan City for free, or a nominal fee, is classified as substantial indirect financing by the State...”, the court held, underscoring how the Club would be bound by 'public oversight' for the aforesaid reason.

The Division Bench, agreeing with the findings of the single judge bench, noted that the land abutting Cubbon Park, granted to the Club free of cost, would be now valued at 'hundreds of crores or even thousands' and the contribution made by the Members of the Club as Membership Fee pales to insignificance in comparison.

“…Therefore, looking into any angle, there is a substantial contribution made by the State i.e. the erstwhile Kingdom of Mysuru, through the Maharaja of Mysuru, who granted 7.5 acre of land to the Century Club. Thereby, the Century Club is for all practical purposes considered to be 'Public Authority' within the definition of 2(h) of the RTI Act. Thus, the provisions of RTI Act are applicable to the Century Club”, the court clarified, confirming the views taken by the single judge bench.

Accordingly, the court dismissed the writ appeal filed by Century Club.

Case Title: Century Club vs. S. Umapathy & Anr.

Case No.: Writ Appeal No. 1351 of 2025 (GM- RES)

Appellant (Century Club): Prashanth Murthy S.G., Advocate

Respondent No. 1: S. Umapathy (Party-in-Person)

Respondent No. 2 (Karnataka Information Commission): Sharath Gowda G.B., Advocate

Citation: 2026 LiveLaw (Kar) 249

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