Right To Information Act (RTI): All India Annual Digest 2025

Update: 2026-02-01 08:30 GMT
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Supreme CourtA request to disclose the marks obtained by other candidates in a public examination under the Right to Information Act, 2005, in the public interest, cannot be declined. Public Information Officer and Registrar v. Onkar Dattatray Kalmankar, 2025 LiveLaw (SC) 210Article 19(1)(a) - Right to Information - Supreme Court examined legal framework on the right to information affirming...

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Supreme Court

A request to disclose the marks obtained by other candidates in a public examination under the Right to Information Act, 2005, in the public interest, cannot be declined. Public Information Officer and Registrar v. Onkar Dattatray Kalmankar, 2025 LiveLaw (SC) 210

Article 19(1)(a) - Right to Information - Supreme Court examined legal framework on the right to information affirming that the right of citizens to know about candidates is a fundamental right under Article 19(1)(a) - This right is essential for a well-informed electorate to make an intelligent decision while exercising their franchise - A fine balance must be struck between the voter's right to information and the sanctity of people's mandate - Minor procedural errors or technical objections should not be allowed to override the mandate of electorate - The will of the people expressed through the election result is sacrosanct and should be respected unless it has been corrupted by fraudulent practices. [Paras 8, 9] Ajmera Shyam v. Kova Laxmi, 2025 LiveLaw (SC) 814 : 2025 INSC 992

Allahabad High Court

Allahabad High Court Allows Withdrawal Of PIL Against Appointment Of SP Gupta As State Information Commissioner

Case title - Ashish Kumar Singh vs. Union Of India Thru. Secy. Deptt. Of Personnel And Tranning New Delhi And 4 Others 2025 LiveLaw (AB) 45

Case Citation: 2025 LiveLaw (AB) 45

The Allahabad High Court dismissed a Public Interest Litigation (PIL) plea as withdrawn, challenging Swatantra Prakash Gupta's appointment as the State Information Commissioner.

The PIL plea, filed by the petitioner in person, Ashish Kumar Singh, challenged Gupta's appointment as the SIC, contending that it violates Section 15(6) of the Right to Information Act, 2005, a provision that bars the pursuit of any profession by an appointee.

Bombay High Court

'Annual General Reports Made By SEBI Cannot Be Disclosed Without Following Procedure U/S 11 Of RTI Act': Bombay High Court

Case Title: Securities and Exchange Board of India vs Central Information Commissioner

Citation: 2025 LiveLaw (Bom) 276

The Bombay High Court has held that before disclosing any information related to third parties, including stock exchanges like NSE and BSE, under the Right to Information Act, 2005 (RTI Act), the concerned authority must strictly comply with the mandatory procedure laid down in Section 11 of the Act. A division bench of Justices Mahesh Sonak and Jitendra Jain passed the ruling in a batch of writ petitions arising from an RTI application filed by transparency activist Subhash Chandra Agarwal seeking information about SEBI's appointment of public interest directors (PIDs) and inspection reports of institutions like BSE, NSE, and MCX.

Information Regarding GST Returns Of Company Cannot Be Disclosed Under RTI Act: Bombay High Court

Case Title: Adarsh Gautam Pimpare vs State of Maharashtra

Citation: 2025 LiveLaw (Bom) 430

The Bombay High Court on Tuesday (October 14) held that a company's Goods and Services Tax (GST) returns filing cannot be disclosed under the Right To Information (RTI) Act. Sitting at Aurangabad bench, single-judge Justice Arun Pednekar noted that section 158(1) of the GST Act prohibits disclosure of information of GST returns to third parties and that section 8(1)(j) of the RTI Act too exempts certain information from being made public unless the information officer is satisfied that the said information must be disclosed as a public interest is involved.

Delhi High Court

Delhi High Court Asks CIC To Decide If 'Ram Janmbhoomi Teerth Kshetra' Trust Is Public Authority Under RTI Act

Title: NEERAJ SHARMA v. PIO MINISTRY OF HOME AFFAIRS JKL DIV AYODHYA SECTION AND ANR.

Citation: 2025 LiveLaw (Del) 124

The Delhi High Court has directed the Central Information Commission (CIC) to decide whether “Shri Ram Janmbhoomi Teerth Kshetra” trust is a public authority under Section 2(h) of the Right to Information Act, 2005.

Justice Sanjeev Narula directed the CIC to decide the question after affording opportunity of hearing to the RTI applicant Neeraj Sharma as well as the Public Information Officer (PIO) of Union Ministry of Home Affairs, as expeditiously as possible.

Info Requiring Analysis Of Legal Proceedings Outside Purview Of RTI Act: Delhi HC Quashes Order To Inform On Ex-Parte Injunctions Given By ADJ

Case title: Public Information Officer Office Of District vs. Harish Lamba

Citation: 2025 LiveLaw (Del) 134

Setting aside CIC's order directing Patiala House Court PIO to furnish information on the number of cases in which a judge granted ex-parte injunction in relation to cases represented by a particular advocate and in suits filed by a particular company, the Delhi High Court observed such queries require an analysis of the relevant judicial proceedings.

It further said that such an analysis sought for in the present case, falls under the Delhi District Courts (Right to Information) Rules, 2008, which exempts disclosure of information when such information does not exist or when it amounts to analyzing the information for the applicant which does not form part of any existing record.

Passport, Personal ID Details Can't Be Disclosed To Third Party Under RTI Act: Delhi High Court

Title: RAKESH KUMAR v. CENTRAL PUBLIC INFORMATION OFFICER AND ANR.

Citation: 2025 LiveLaw (Del) 183

The Delhi High Court has ruled that details about passport and personal identification documents cannot be disclosed to a third party under the Right to Information Act, 2005.

Justice Sachin Datta referred to various judgments on the issue and said: “…disclosures which may be sought by a third party under the provisions of RTI act pertaining to passport or any other personal identification document, squarely falls under the ambit of Section 8(1)(j) of the RTI Act.

Ensure RTI Information Is Provided In Modes Sought, With Adequate Safety Measures: Delhi High Court To Centre

Title: Aditya Chauhan & Anr v. Union of India & Anr

Citation: 2025 LiveLaw (Del) 733

The Delhi High Court directed the competent authority of the Union Government to take measures and issue directions of frame Rules to ensure that the information under the Right to Information Act (2005) is provided in the mode sought by the information seeker, while also ensuring adequate safety measures.

A division bench comprising Chief Justice DK Upadhyaya and Justice Tushar Rao Gedela directed the competent authority of the Government of India to take a decision on the issue within three months.

RTI Act | Central Information Commission Cannot Make 'Policy Prescriptions' To Any Public Authority: Delhi High Court

Case title: Hindustan Petroleum Corporation Limited & Ors v. Mr Siddhartha Mukherjee

Citation: 2025 LiveLaw (Del) 898

The Delhi High Court has made it clear that the role of the Central Information Commission constituted under the Right to Information Act 2005 is to ensure transparency and disclosure of information by a public authority, and not make policy prescriptions.

Information On SEBI's Internal Probe Into Alleged Insider Trading Exempted From Disclosure Under RTI Act: Delhi High Court

Case title: Srishti Rustagi v. SEBI

Citation: 2025 LiveLaw (Del) 1146

The Delhi High Court has held that information pertaining to internal investigation being conducted by the Securities and Exchange Board of India (SEBI) is exempt from disclosure under the Right to Information Act, 2005.

Case Title: Reetam Singh v. The State of Assam & 4 Ors.

Citation: 2025 LiveLaw (Gau) 14

The Gauhati High Court recently directed the State Authorities to complete the process of enrolling the Public Information Officers (PIOs) and the other Departments on the online RTI Portal, who have not enrolled to date, and also to make a provision expeditiously for uploading the supporting documents as directory instead of mandatory.

The division bench comprising Chief Justice Vijay Bishnoi and Justice N. Unni Krishnan Nair was hearing a PIL raising a concern that the State authorities have not complied with the order dated March 20, 2023, passed by the Supreme Court in Pravasi Legal Cell v. Union of India & Ors. WP(C) No.1040/2019

Jharkhand High Court

Penalty Under RTI Act Cannot Be Imposed Without Notifying Responsible Officer: Jharkhand HC Sets Aside ₹25k Fine On Addl Dy Commissioner

Case Title: Ganesh Kumar vs The State of Jharkhand and ors

LL Citation: 2025 LiveLaw (Jha) 24

The Jharkhand High Court has held that a penalty under Section 20(1) of the Right to Information Act, 2005, cannot be imposed without first issuing notice to the officer actually responsible for the delay in furnishing information.

Justice Sujit Narayan Prasad, setting aside a ₹25,000 penalty imposed on Ganesh Kumar, the then Additional Deputy Commissioner of East Singhbhum, said, “for the purpose of achieving the object of the Act and to maintain the provision of Section 20(1) by way of deterrent measure, a notice ought to have been issued to the Addl. Deputy Commissioner, the present petitioner and the Circle Officer in order to assess that who is at fault.”

Karnataka High Court

S. 91 CRPC | Accused Cannot Be Directed To Secure Documents Related To Case From Authorities Using RTI Act: Karnataka HC

Case Title: Dr Shivamurthy Muruga Sharanaru AND State of Karnataka

Case No: CRIMINAL PETITION NO. 1639 OF 2025.

Citation No: 2025 LiveLaw (Kar) 65

The Karnataka High Court has said that an accused should not be driven for securing documents related to his case under the Right to Information Act, when an application is filed under Section 91 of the Criminal Procedure Code.

A single judge, Justice M Nagaprasanna held thus while allowing a petition filed by the pontiff of Murugha Mutt of Chitradurga, Dr Shivamurthy Muruga Sharanaru, who is accused of sexually abusing two minor girls staying in the hostels run by the Mutt.

The petitioner had challenged the order of the trial court rejecting his application seeking the summoning of certain documents related to the investigation in the case. The prosecution had opposed the plea saying the petitioner could have secured them by filing an application Under the Right to Information Act, 2005.

Bengaluru's Century Club Built On Land Granted By Maharaja Of Mysore, Is Public Authority Under RTI Act: Karnataka High Court

Case Title: Century Club AND S Umapathy & ANR

Case No: WRIT PETITION NO. 13336 OF 2018

Citation No: 2025 LiveLaw (Kar) 247

The Karnataka High Court has held that Bengaluru's Century Club, which is situated abutting Cubbon Park and is built on land granted by the then Maharaja of Mysore in 1913, is public authority under the Right To Information Act and is thus bound to furnish information.

Dismissing the Club's petition against an order directing it to provide information under the Act, Justice Suraj Govindaraj in his order said: “The grant of land on which petitioner club is situated would amount to a substantial contribution of financing by the State, made by the then Maharaja of Mysore, for making the RTI Act applicable to the petitioner club.

Karnataka High Court Holds RTI Act Applies To Nirmiti Kendras, Slaps ₹50K Costs For Denying Information

Case Title: PIO & THE PROJECT DIRECTOR NIRMITI KENDRA AND THE STATE INFORMATION COMMISSIONER & Others

Case No: WRIT PETITION NO. 52581 OF 2017

Citation No: 2025 LiveLaw (Kar) 277

The Karnataka High Court has held that Nirmiti Kendras qualify as 'public authority' in terms of Section 2(h) of the Right To Information Act and thus, they are bound to disclose available information under the Act.

For context, the object of Nirmiti Kendra is to develop skills in the construction area and carry out civil contracts assigned by the State.

Justice Suraj Govindaraj dismissed the petition filed by the Public Information Officer of the Kendra, who had approached the court challenging an order of the State Information Commissioner directing it to provide necessary information sought for by the applicant.

Copy Of Passport Can't Be Given To Third Party Under RTI Act: Karnataka High Court

Case Title: Prakash Chimanlal Sheth AND State of Karnataka & Others

Case No: WRIT PETITION NO. 17341 OF 2025

Citation No: 2025 LiveLaw (Kar) 366

The Karnataka High Court has said that information relating to the passport of a person accused of cheque dishonour, including a copy of the passport is personal in nature and cannot be disclosed under the Right to Information Act.

The court also observed that the disclosure was exempted under Section 8(1)(h) as being information the disclosure of which would impede the probe and Section 24(4) as per which the Act is not applicable on special intelligence and security organization/units organized and established by the State Government.

Justice Suraj Govindaraj said: “The disclosure of the information like a passport, in my considered opinion, being personal in nature would cause immense harm and injury to a person. The details of a passport are private to a person and if those details of a passport are made available to any third party, including the petitioner who has filed Section 138 of NI Act proceedings, it could cause a danger to the life or physical safety of the concerned person.”

RTI Not A Tool To Obtain Others' Exam Answer Sheets: Karnataka High Court Rejects Activist's Plea For KPSC Answer Script Disclosure

Case Title: INTAK RAJU N AND KARNATAKA INFORMATION COMMISSION & Others

Case No: WRIT PETITION NO. 26292 OF 2025

Citation No: 2025 LiveLaw (Kar) 413

The Karnataka High Court recently said that merely being a Right to Information activist would not give a person the right to seek answer scripts of a person who had appeared for the exam conducted by the Karnataka Public Service Commission (KPSC).

A single judge, Justice Suraj Govindaraj said thus while dismissing the petition filed by one Intak Raju N, who claimed to be a RTI activist and President of the Mysore District Right to Information and Human Rights Protection Association.

Kerala High Court

Info Which Though Not In Possession But Can Be Accessed By Co-Operative Society Registrar Can Be Sought Under RTI: Kerala High Court

Case Title: The Muppathadam Service Co-operative Bank v The State Chief Information and Others

Citation: 2025 LiveLaw (Ker) 266

The Kerala High Court has said that information which can be accessed by the Registrar of the Co-operative Society is also an information which can be sought through a Right To Information (RTI) Application.

A division bench of Chief Justice Nitin Jamdar and Justice S. Manu relied on Supreme Court decision in Thalappalam Service Cooperative Bank Limited and Others v State of Kerala and Others (2013) which held that the information which is accessible to the Registrar as per the the Kerala Cooperative Societies Act, 1969 can be considered as information which is held or under the control of public authority.

CIC Appointed Prior To 2019 RTI Amendment Act Entitled To Pensionary Benefits Equivalent To Retired Supreme Court Judge: Kerala High Court

Case Title: Vinson M. Paul v State of Kerala and Another

Citation: 2025 LiveLaw (Ker) 270

The Kerala High Court quashed State Government's letter to the former State Chief Information Commissioner (SCIC) informing him that he cannot be given pensionary benefits equivalent to a retired Supreme Court Judge.

Justice Harisankar V. Menon said that even after the amendment, the pensionary benefits of the petitioner are unchanged on account of the 2 provisos.

Public Information Officer Not Legally Bound To Start Investigative Process U/S 7 Of RTI Act: Kerala High Court

Case Title: Dr. Muhammed Thaha v. The Director of Collegiate Education and others

Citation: 2025 LiveLaw (Ker) 276

The Kerala High Court in a recent decision held that the Public Information Officer does not have any power or duty under section 7 of the Right to Information Act, 2005 to open up an investigation while processing and disposing RTI Applications.

The judgment was passed by Justice N. Nagaresh while hearing a Writ Petition seeking a direction against the respondents to approve the appointment of the petitioner as Principal of the respondent College.

Cochin International Airport Ltd A 'Public Authority' Under RTI Act : Kerala High Court

Case Title: M/s Cochin International Airport Ltd. v. State Information Commission and Ors. and connected cases

Citation: 2025 LiveLaw (Ker) 486

The Kerala High Court has recently held that the Cochin International Airport (CIAL) is a public authority coming within the purview of the Right to Information Act, 2005.

Dismissing the writ appeals preferred by CIAL challenging the decision of the Single Bench, the Division Bench comprising Justice Sushrut Arvind Dharmadhikari and Justice Syam Kumar V.M. imposed a cost of Rupees one lakh on CIAL for filing the writ appeals without proper authority.

Madhya Pradesh High Court

Attempt To Shield Ineligible Persons: MP High Court Quashes CIC Order Denying RTI Info On Experience Certificate Of Public Office Appointees

Case Title: Dr. Jayshree Dubey vs. The Central Information Commissioner And Others

Citation: 2025 LiveLaw (MP) 79

The Madhya Pradesh High Court quashed an order of the Central Information Commission which denied information to an applicant under RTI Act pertaining to educational qualification including experience certificate of candidates appointed to public office, holding that the same cannot be termed as private information.

In doing so the court said that the stand taken by the Central Information Commission in denying the information to the petitioner, which was permitted as per Section 11(1) proviso and going against earlier CIC orders, appears to be an attempt for nondisclosure of information and "an attempt to shield unscrupulous and ineligible persons".

MP High Court Quashes Remarks Against Ex-State CIC's Conduct For Delaying RTI Info, Says Decision Was 'Bona Fide'

Case Title: Arvind Kumar Shukla v Neeraj Nigam

Citation: 2025 LiveLaw (MP) 136

The Madhya Pradesh High Court set aside adverse observations made on the conduct of former State Chief Information Commissioner (CIC) Arvind Kumar Shukla in an order passed by a single judge bench and quashed the direction to recover a penalty of Rs. 40,000.

A division bench of Acting Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf observed that the order passed by the CIC with respect to information sought by an RTI applicant was passed in bona fide discharge of his duties.

Madras High Court

Public Information Under RTI Act Cannot Be Classified As Company's Official Document: Madras High Court

Case Title: The Manager v. Aron K Thiraviaraj

Citation: 2025 LiveLaw (Mad) 357

The Madras High Court recently upheld an order of a single judge setting aside the departmental proceeding against a man for pasting the information related to the party on the notice board.

The bench of Justice CV Karthikeyan and Justice R Vijayakumar noted that the information, that was disclosed under the Right to Information Act would not be an “official document” of the company, or that relating to the company's internal operations. The court added that the information was already available in the public and was lawfully disclosed and pasting such information in the company's notice board would not be violative of the standing orders.

Orissa High Court

'Apathy Of Highest Order': Orissa High Court Criticizes Arbitrary Dropping Of RTI Proceeding By Information Commission

Case Title: Hemanta Nayak v. State of Odisha & Ors.

Citation: 2025 LiveLaw (Ori) 127

The Orissa High Court came down heavily on the State Information Commission (SIC) for its apathetic and arbitrary attitude in denying/dropping a plea made under the Right to Information Act ('RTI Act') way back in 2018. While highlighting the contradictory stand taken by the Commission in order to avoid providing information, the Bench of Justice V. Narasingh observed –

“In the factual backdrop of the case at hand, this Court is constrained to observe that in rendering the impugned decision the State Information Commission allowed its finding to be entrapped in officialdom and red tapism, which are illegitimate tools to fall back, to deny response to an application under the RTI Act, 2005 and thereby render the provisions nugatory.”

Patna High Court

S.19(8)(b) RTI Act | No Compensation Can Be Granted Unless Actual Loss Or Detriment Due To Delayed Information Shown: Patna High Court

Title: Amit Anand v. Bihar Information Commission and Ors

Citation: 2025 LiveLaw (Pat) 34

While dismissing a petition filed by an individual seeking compensation for delayed information under the Right to Information Act 2005, the Patna High Court has reiterated that compensation under Section 19(8)(b) of the Act can only be granted when the applicant demonstrates actual loss or detriment suffered due to the delay in receiving the requested information.

Justice Rajesh Kumar Verma presiding over the case observed, “this Court has come to the conclusion that the petitioner has not produced/demonstrated the extent of loss or detriment suffered by him for award of compensation under Section 19(8)(b) of the RTI Act, 2005 and apart from that, the petitioner has not challenged the order dated 16.08.2019 by which the appeal of the petitioner was disposed of by the State Information Commission without awarding the compensation under Section 19(8)(b) of the RTI Act, 2005.”

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