The Punjab and Haryana High Court has dismissed a writ petition challenging the Punjab State Information Commission's refusal to furnish RTI information relating to an FIR, holding that an applicant's claim that the information would assist him in pending civil litigation does not, by itself, establish the larger public interest necessary to override the third-party information exemption under Section 8(1)(j) of the RTI Act.

Justice Kirti Singh said, "The fact that the information may be useful to a litigant in connection with pending proceedings cannot, without more, convert a private requirement for documents into a larger public interest within the meaning of the exemption framework under the RTI Act, which does not contemplate disclosure of third-party information merely because the applicant considers it useful for advancing his case in another proceeding."

The petitioner had filed an RTI application seeking copies of all actions taken by the Police Department and the Government of Punjab in response to FIR No.0093 dated 22.11.2024, registered at Police Station Kheri Gandian, District Patiala — from the filing of the complaint/FIR until the information was furnished. The FIR concerned an incident dated 13.11.2024, with one Jasvir Ram as the complainant and unknown persons shown as accused; the petitioner was neither the complainant nor named as an accused. When no information was furnished within the statutory period, the petitioner pursued a first appeal and thereafter a second appeal before the State Information Commission.

Before the Commission, the police authorities objected that the information constituted third-party information exempt under Section 8(1)(j) of the RTI Act, and placed on record a letter along with an affidavit stating that a settlement had taken place between the parties concerned, with the complainant furnishing an affidavit to that effect. On this basis, the Commission declined disclosure and disposed of the second appeal on 05.08.2026.

Counsel for the petitioner argued that the information sought concerned action taken by public authorities pursuant to an FIR and could not be treated as private merely because the petitioner was not a named party, and that Section 6(2) of the RTI Act does not require an applicant to disclose reasons for seeking information or demonstrate personal interest, submitting further that the information had a direct bearing on pending civil proceedings concerning the affected landowners.

The Court held that while Section 6(2) indeed frees an applicant from disclosing the purpose behind an RTI request, this cannot be read as conferring "an unrestricted right to disclosure notwithstanding the exemptions specifically contemplated by Section 8 of the RTI Act" — the absence of a duty to state reasons is distinct from the separate question of whether the information sought is otherwise exempt.

The Court noted the request was not confined to the FIR copy (a public document) but sought the entire action-taken record, inherently likely to include material concerning the complainant and other persons involved, material the Commission was entitled to examine on its actual nature and contents, since being held by a public authority does not automatically render every part of a record disclosable.

On the petitioner's locus argument, the Court held the Commission had not declined the request solely for lack of standing, but had considered the nature of the information and the third-party exemption objection, with the petitioner's status being only one relevant circumstance.

The Court noted the petitioner's own RTI application and subsequent submissions indicated the information was sought for use in media or before other fora/courts in connection with the pending civil litigation, reinforcing that this was a private litigation interest rather than a demonstrated larger public interest.

On the scope of its own jurisdiction, the Court reiterated that under Articles 226/227, it does not sit as an appellate authority over the Information Commission, and interferes only where the order suffers from patent legal error, perversity, jurisdictional infirmity, non-application of mind, or violation of natural justice — none of which were shown to exist here, since the Commission had duly considered the police's objection, the petitioner's status, the settlement material, and the nature of the information sought.

Finding no ground to interfere with the Commission's order, the Court dismissed the writ petition, clarifying that it expressed no opinion on the merits of the underlying land dispute, the pending civil proceedings, the FIR allegations, or the settlement between the parties, its consideration being confined strictly to the legality of the RTI decision.

Title: Pavitar Singh v. Punjab State Information Commission and Others

Mr. Raj Kaushik, Advocate for the petitioner.

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