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SUPREME COURT JUDGEMENTS ON RIGHT TO INFORMATION

‘The right to know is the right to live.’ Quoted Aruna Roy. This comes in light as we discuss different facets of the
following act, that is, Right to Information Act, 2005.

INTRODUCTION

India is world’s largest democracy and this gives its citizens innumerable rights. There are rights for every facet
involved in our daily lives. However, our rights are of no use if we do not have access to information related to
transparency of working of the government. With this point of view and in order to introduce more transparency
and accountability in the system, Government of India has made an act named Right to Information. This right is
granted to every Indian citizen under article 19(1)(a), that is, “All citizens shall have the right to freedom and
expression.”1 Ergo, an act was enacted by the Government of India named ‘The Right to Information Act, 2005’ to
realize the concept of Right to Information. Also, the very point of democracy ‘Government by the people’ makes
it essential that dwellers here, have access to the information on matters concerned with the public. It brings into
existence the shape for ‘open governance’ which is a substructure to democracy.

Right to Information Act 2005 is an act which gives its citizens a right to access information which comes under
the control of any public authority and it gives its citizens a right to:

i. Inspect work, documents, and records;

ii. Take notes, extracts, or certified copies of documents;
iii. Take certified samples of material;
iv. Obtain information in any form of electronic mode or with help of printouts where such information is
stored in a computer or in any different device.2

Type of Information obtainable under Right to Information act, 2005: section 2(f) of the act clarifies the
information that can be acquired with this act. The information includes any material in any form inclusive of
records, documents, memos, e-mails, opinions, advices, press releases, circulars, orders, log books, contracts,
reports, papers, samples, models, data material held in any electronic form and information about private entity,
1
India CONST. art. 19, cl. 1, sub-cl. A.
2
https://cic.gov.in/faq#n3411
only if it can be accessed by public authority under any other law. When one seeks for any information under RTI
act, that person must pay a fee of rupees 10 along with application in various forms like demand draft, banker’s
cheque, Indian postal order or cash, payable to the Public Information Officer and certain amount is payable
according to the services one avails like charges for copying, samples, etc.

Here, section 8 of the act mentions certain points which put restrictions on disclosure of some documents. These
are basically related to personal information of an individual which have no relation with larger public interest.

According to section 3 of the Right to Information Act, 2005 any Indian citizen can seek information under this
act. So this act excludes the foreign people who reside here without citizenship.

If in any case a request for information is denied then according to section 19 (5) of the Right to Information Act,
onus to prove justifiability of denial lies on the CPIO who denied the same request. 3

Evolution of Right to Information Act in India

Need for right to information arose as access to information was realised as a vital tool to fight corruption and
wrongdoings as most of the times due to lack of evidence and information many corrupt leaders escaped the wrath
of law. Sections 4(1), 5(1), 5(2), 12, 13, 15, 16, 24, 27 and 28 of the said act came into force on 15 th June, 2005;
whereas remaining provisions of the act came into force on 12 th October, 2005. Interestingly, on October, 12, 2005
itself a person named Shahid Raza Burney submitted India’s first Right to Information application at a police
station in Pune and this way RTI was formally a part of Indian Democracy.

But before right to Information Act we have a vivid history to have this level of transparency and accountability.
Certain people of different strata of the society worked really hard to make accessibility a right. Before the
commencement of this act many states like Goa, Karnataka, Delhi, Assam, Rajasthan, and all already had their own
right to information act. In January 2003 the President assented to the Central Freedom of Information Act, 2002.
Unfortunately, the act was never notified and thus it never became effective.

However, in May 2004 when UPA came to power at national level, it brought out Common Minimum Programme
which along with other benefits promised to provide a government that is corruption-free, transparent and
accountable. After several meetings with ministries and Prime Minister, government introduced revised Right to
Information Bill in Parliament on 22 December 2004. Howbeit, this bill was only applicable on the central
government and not on the states. Thus the Right to Information bill was amended and on 15 June 2005 it got
assent by the President and on 13 October, 2005 it became fully operational.4

ROLE OF SUPREME COURT IN MAKING RIGHT TO INFORMATION ACT A SUCCESS

3
The Right to Information (Amendment) Act, 2019, No. 24, Acts of Parliament, 2019.
4
Stuti_98, Evolution and Development of the Right to Information Act in India, LEGAL SERVICE INDIA,
http://www.legalserviceindia.com/legal/article-323-evolution-and-development-of-the-right-to-information-act-in-india.html.
Transparency advocates and people who have been benefitted from the same have always appreciated Supreme
Court of India for its inseparable role in helping people understand the real potential of Right to Information and it
also made the people realise that right to information is a fundamental right of every citizen under Article 19(1)(a).
Though the act provides access to most of the information still sections 8 and 9 of the RTI act is an exception. It
states the information which is restricted and cannot be provided to everyone unless it is for larger public interest. 5

Ergo, this research paper analyses a few Supreme Court cases which will help in understanding how certain
questions are answered by the decided cases and help us navigate when one is in confusion regarding certain
matters like education, access to other’s information and all.

SUPREME COURT CASES

1. Girish Ramchandra Deshpande v Central Information Commissioner &Ors.6

FACTS= The petitioner had, in this case, submitted an application before the Regional Provident fund
Commissioner, Ministry of Labour, Government of India, to call for various details relating to the third
respondent who was employed as Enforcement Officer in Sub-Regional Office, Akola. Information sought
included details about investment, salary, returns, movable and immovable property, gifts received by that
person and so on. This application was rejected under section 8(1)(a) of RTI Act by Regional Provident
Fund Commissioner, Nagpur. On denial petitioner approached Chief Information Commissioner and so on
and finally this case was filed in the Supreme Court of India.
ISSUE= whether the aforesaid information sought by the appellant can be treated as personal information
under clause (j) of section 8(1)of the RTI Act? Also a question arises that was it right to deny information
regarding third party’s personal stuff by CIC ?
HELD= it was observed that the information asked for by the petitioner is qualified as personal information
under RTI Act as it finds a place in the income tax returns of third respondent. Here, case called Milap
Choraria v Central Board of Direct Taxes was considered and income tax return was held to be personal
information exempted under section 8(1)(j) of RTI Act. It was also held that performance of employee of an
organisation is primarily a matter between the employee and the employer and this aspect falls under
personal information only. Personal information can be disclosed only if the CIC or CPIO is convinced that
larger public interest is related to the disclosure then the requisite orders could be passed but one could not
claim those details as a matter of right. Since the petitioner in the instant case could not succeed in
establishing that information asked for is in larger public interest so the special leave petition was
accordingly dismissed.
ANALYSIS= this case concerns with scope and interpretation of clause (e), (g), (j) of section 8 of RTI Act.
This case seems to neither have any ratio decidendi, nor does it have any principle with reasons. Thus, this
5
Sahilesh Gandhi, Critical Analysis Of Supreme Court Judgements on the RTI Act, 2005 – Wither Transparency, PUBLIC DOMAIN,
https://satyamevajayate.info/wp-content/uploads/2017/08/Analysis-of-Supreme-Court-judgments-on-RTI.pdf
6
2013 1 SCC 212.
 must not be used as a precedent. Here, respondent no. 3 was a public officer and so he is counted as a part
of the system. We see whether information can be disclosed to the parliament or legislature or not and if it
can be disclosed to the public authorities like the MPs or the MLAs, then it shows the likely harm is not a
real threat since what is given to the legislature will be in public domain. Also on analysing section 8(2) of
the act, it can be made out that public authority can allow access to information, in case public interest
overweighs harm to the protected interest. On reading the case R Rajagopal and Anr.v State of Tamil Nadu 7
it can be concluded that under Public Records Act, privacy can be claimed only in rare cases. Also section
8(1)(j) of the RTI Act does not fully exempt personal information if it is related to public good. In this case
we see that the information sought by the petitioner finds its place in Income Tax Returns and this means
that the information is exposed to the Legislature so it must not be denied to the common people too. Since
Right to Information act is all about transparency and accountability then public authorities should also be
transparent and accountable. Respndent no.3’s claims of infringement of Right to Privacy fall flat on seeing
that governments of Bihar and Gujarat display the assets of all their officials on their website. So when
petitioner asks for information about this public official it cannot be termed as infringement of his privacy.
This case cannot be termed as a right basis for making any law as this judgement is based only on CIC’s
and CPIO’s subjective reasoning. Therefore, this judgement violates the principal objective of the RTI Act
and is restrictive of citizen’s fundamental rights.

2. Canara Bank Rep. By its Deputy Gen. Manager vs C.S. Shyam &Anr.8
FACTS= In the following case the appellant is nationalized bank named Canara Bank; and respondent 1
was working as a clerical staff in Malappuram (Kerala) branch of the same bank. On 01.08.2006 respondent
no. 1 submitted an application to the PIO of bank under section 6 of RTI Act, asking for information about
transfer and posting of entire clerical staff from 01.01.2002 till 31.07.2006 in all branches of the bank. The
said information had 15 parameters about personal information like a candidate’s date of joining, details of
his promotion, his earning and all. Since information included details of personal information too, therefore,
PIO expressed his inability to furnish details for details were protected under section 8(1)(a) of RTI Act.
Aggrieved by the decision, respondent no. 1 carried the matter to CPIO who agreed with the PIO and
dismissed the appeal. Then he carried the matter to the Central Information Commissioner and appeal was
allowed, thus, directing the bank to furnish the asked information. Later the bank filled a writ petition
before High Court and it was dismissed. This way finally an appeal was filed in the Supreme Court.
ISSUE= The issue arising in this case is whether the information sought for in the present case is personal
in nature and thus be protected under section 8(1)(a) of RTI Act or not?
HELD= the judgement passed herein dismissed the application by respondent 1 under section 6 of RTI Act.
The decision was made by considering two decisions, that is, Girish Ramchandra Deshpande v Central
7
1994 SCC (6) 632.
8
AIR 2017 SC 4040.
 Information Commissioner &Ors.; and R.K. Jain v Union of India &Anr. After looking upon the two cases
an opinion was formed that the information so asked could not be sought as it was rejected under section
8(1)(a) of the act as the information sought here was personal in nature and that respondent no. 1 could not
disclose any interest larger than the public interest involved. Thus, the application was rejected in this case.
ANALYSIS= after reading this case, one can easily draw a line between the information which is personal
in nature and the one which is not. The main distinction drawn here is that information such as the salary
drawn by a person or the basis on which he was promoted or the kinds of rules he is made to follow in the
organisation are personal in nature. This is so as employee and employer share a fiduciary relationship and
this is a personal matter which does not involve larger public interest.

3. The Institute of Chartered Accountants of India v Shaunak H. Satya & Ors.9

FACTS= In this case ICAI is a corporate body established under section 3 of Chartered Accountants Act,
1949. One of the functions performed by the body is to conduct exam of candidates for enrolment as
Chartered Accountant. Respondent no. 1 couldn’t succeed in examination and applied for verification of
marks which was carried out by the appellant. Appellant submitted an application seeking information
under 13 heads out of which information could not be given following points:- (3) instructions given to the
examiners and moderators; (5) modal answers, if any, given to examiners and moderators; (13)number of
times council has revised marks of any candidate according to regulation 39(2) of Chartered Accountants
regulation,1988, the criteria used for such discretion, quantum of revision affected by such revision in last 5
exams, held at all levels. The appellant’s main defence for denial was that of confidentiality. On being
dissatisfied by this reply, respondent filed an appeal respectively before CPIO, CIC. CIC reasoned that
instructions issued are confidential and sections 8(1)(d) and 8(1)(e) are applicable. On approaching Bombay
High Court, petition’s appeal was allowed and appellant was asked to furnish the asked information.
Finally, the appellant approached the Supreme Court and here appeal was granted.
ISSUE=
i. Whether instructions, solutions to questions given by ICAI to examiners and moderators are
intellectual property, therefore exempted under S.8(1)(d) RTI Act?
ii. Whether access to the said information would cause copyright infringement under S.9 RTI Act?
iii. Whether instructions, solutions are made available in fiduciary capacity, that is, S.8(1)(e) of RTI
Act?
iv. Was it justified to ask to furnish information under query 13 by High Court?

HELD=

9
(2011) 8 SCC 781.
 i. Question papers and instructions are literary work that is product of human intellect, thus subject to
copyright. These items being intellectual property of ICAI under S.8(1)(d). But here respondent 1
not in dispute with claim of copyright. Here it was held that S.8(1)(d) of RTI Act doesn’t bar
disclosure of question papers, modal answers, after exam and evaluation of answer script is
completed so that competitive position of third party is not harmed as information available cannot
remain undisclosed forever. Also, appellant papers are disclosed to everyone during conduction and
appellant voluntarily publishes “suggested answers” as a book for sale every year after the exam.
ii. It was reasoned that S.9 of RTI Act doesn’t apply here. ICAI not entitled of protection under S.9 as
providing information in respect of which ICAI holds a copyright subsisting in person other than
state. Upon combined reading of S.51 and S.52(1)(a) of Copyright Act 10 shows that furnishing of
information by examining body, in response to a query under the RTI Act may not br infringement
of copyright.
iii. Information available to a person in fiduciary relationship is exempted from disclosure under S.8(1)
(e) of RTI Act. One can refer to the case- CBSE v Aditya Bandopadhyay which says that
instructions and questions are ICAI’s intellectual property, thus examiners and moderators need to
keep absolute secrecy and the same must not be disclosed. Examiners and moderators are in
position of agent and ICAI acts as principle and when anything is given and taken in trust,
expecting secrecy and confidentiality to be maintained in that behalf is help by recipient in
fiduciary relationship. Here instructions and solutions to the questions communicated by examining
body to examiners and moderators are information given in fiduciary relationship and is exempted
from disclosure under S.8(1)(e) of RTI Act.
iv. Regulation 39(2) of Chartered Accountants regulations, 1988 says that council may in own
discretion revise marks obtained by all or a section of candidates in a manner that may be necessary
for maintaining its standards of pass percentage provided in regulation. The court explained
standard moderation process in- Sanjay Singh v. U.P. Public Service Commission 11 by telling
‘Hawk-Dove effect’ which says a variability in marks arises when different examiners evaluate
answer scripts. Thus process of moderation must be used to reduce examiner subjectivity or
variability.
Ergo, information sought under (i), (iii), (v) of query 13 were not maintained and was not available
in data form with appellant in its records, ICAI was not bound to furnish the same. Appeal was
allowed in part and order of CIC was restored with modification regarding query (13): ICAI to
disclose the first respondent, the standard criteria, relating to moderation, employed by it, for the
purpose of making revisions under Regulation 39(2).

10
The Copyright (Amendment) Act, 2012, No. 27, Acts of Parliament, 2012.
11
2007 (3) SCC 720.
 ANALYSIS= on reading this case we can understand the facets where RT Act becomes ineffective and the
concept of transparency fades away. The information sought by the respondent could not be obtained for it being of
fiduciary relation and it was sought by one single person. Had the same information (instructions, solutions) been
sought by several people, it could have justified that it is for a large public interest. Also the appellant took a
defence that it cannot furnish the information as it would cause unnecessary work load for their already tight
schedules. This statement is a proof that how transparency and accountability is compromised by many by taking a
defence of workload. This attitude has rightly been condoned by the Supreme Court and interpretation of the
section and the act as a whole has been done aptly.

4. Central Board of Secondary Education v. Aditya Bandopadhyay.12

FACTS= Respondent 1 appeared for Secondary School Examination, 2008 conducted by Central Board of
Secondary Education (appellant). After getting the result, he was dissatisfied with his marks so he made an
application for inspection and re-evaluation of marks of his answer books. The same application was
rejected by the appellant. The reasons stated for rejection were that information sought was exempted under
S.8(1)(e) of RTI Act; examination Bye-laws of the Board said that no candidate is entitled to re-evaluation,
disclosure or inspection of answer book(s). Then respondent 1 filed an application before the Calcutta High
Court. The appellant resisted the petition stating its Bye-law No. 61 which mainly states that no candidate
shall be entitled to revaluation or disclosure or inspection of answer book; it allowed only verification of
marks with certain conditions applied to the same. The appellant also claimed that their paper is set by well
experienced teachers and the checking is autonomous. They said that re-evaluation was impossible
administratively and the procedure used by it ensures accuracy and fairness. So accordingly denial for re-
evaluation was not unfair. The High Court directed appellant to grant inspection of answer books but the
plea of re-evaluation was rejected as it was an ensuing relief, not provided under RTI Act. Eventually
CBSE filled appeal by special leave.
ISSUES=
 Whether examining body evaluated answer sheets in fiduciary relationship and consequently S.8(1)
(e) is applicable or not?
 If examinee was entitled to inspect answer sheets, whether such right was subject to any limitations?

HELD= It was held that examining body does not hold evaluated answer-sheets in a fiduciary
relationship. Copious cases were referred and intelligible reasoning was done to reach the decision. It was told
that when answer-sheet is evaluated by an examiner selected by examining body, the evaluated answer-sheet
becomes a record comprising the ‘opinion’ of the examiner and thus, evaluated answer-sheet is‘information’ under
the RTI Act. Ergo, examining can claim exemption only under S8(1) as examining bodies are not covered under
12
(2011) 8 SCC 497.
S24 and also information sought is not covered in S9. Also re-evaluation was not available under RTI Act. So one
more option was of inspecting that was available under RTI Act as answer-sheets were ‘information’ therefore, its
certified copies could also be taken. S.22 of RTI Act provides that provisions of the Act will have effect,
notwithstanding anything inconsistent contained in other law for the time being in force. For not making answer-
sheets available for inspection, the Board had to show that they fall under exempted category described in S.8(1)(e)
of the RTI ACT. Duty of the examining body is to test candidates who have completed course of study and verify
whether they have successfully completed or passed that course of study. Hence it was said that the examining
body was not in a fiduciary relationship either with the examinee who participated in the examination and whose
answer-sheets were evaluated by the examining body. The claim by the examining body that even if there is no
fiduciary relationship between the examining body and them, still they had a fiduciary relationship with the
examiner. This claim was found to be meritless and so this contention could not be validated. The Supreme Court
showed concern that RTI Act should not be misused for obstructing nation’s growth by engaging the officials to
gather information and consume their 75% of time. Finally the Supreme Court affirmed the order of the High
Court directing the examining bodies to permit examinees to have inspection of their answer book.

ANALYSIS= In this case Supreme Court has given a decision which was unaffected by certain landmark cases
decided earlier as they were not interpreting the real meaning of the RTI Act. This judgement has also opened ways
for many who are intimidated by the fear of not getting the desired result after a long and expensive court trial. At
the same time this judgement has anomaly which said that RTI Act should not be misused by the citizens. This
statement has been quoted by many PIOs and CPIOs to reject even some legitimate RTI applications. Since not
many people file for RTI applications in India, so even if one application takes a long time, still the RTI officers
have enough time to complete their other tasks. Perhaps not a large number of staff is required for doing this public
work. In a democratic country like ours if credibility of people is questioned this way then a threat lies on
transparency and accountability. Thus, just like this win people must get the information that they can ought for
their betterment and more transparency and accountability.

5. Chief Information Commr. & Anr vs State Of Manipur & Anr.13

FACTS: On 9th February, 2007 appellant no. 2 Mr. Wahangbam Joykumar filed a demand application
under sec 6 of the RTI Act to acquire information through the Information Officer of State in relation to the
magisterial enquiries initiated by the Government of Manipur from 1980-2006. When his request received
no response he filed complaint under section 18 of RTI act in front of the State Chief Information
Commissioner but his order directing respondent 2 to furnish the said information was challenged by state
by filing of a Writ Petition. A 2nd complaint was filed on 19th May 2007 by appellant No. 2 to receive the
similar information but for a period from 1980 to 2007 march, and when got no response he filed a

13
AIR 2012 SC 864
 complaint again under section 18 and like earlier this time too the complaint was disposed of by the order
dated 14th august 2007 directing the disclosure of the said information sought for within just 15 days. This
time too the order was challenged through a Writ Petition by the respondents. Both of these writ petitions
were heard in the High Court of Guwahati by a learned single Judge who dismissed them through a
common order dated 16 Nov 2007 by upholding the order, inter alia, of the commissioner.
After this, the writ appeal was filed against both of the judgements which was heard by the Division Bench
consisting of Justice Asok Kumar Ganguly and Justice Gyan Sudha Mishra. The issue in front of them was:
ISSUE: Whether or not the Commissioner of Information can direct the declaration of information whe
complaint has been made under section 18 of the RTI Act.
HELD: Through the impugned order of the high court it was held that u/s 18 of the RTI Act the
Commissioner has no power to direct the respondent regarding furnishing the information as this power is
conferred u/s 19(8) of the Act. Hence , no information can be directed to be given in complaints made u/s
18 of the RTI Act.
ANALYSIS: The information that was sought by the applicant was concerned with number of magisterial
enquiries instituted under Commission of Inquiry Act, 1952 by Manipur Govt. between 1980-2006. On not
getting a response even after the statutory time period lapsed, a complaint was filed. The Information
Commissioner ordered info to be given. High Court’s single judge bench upheld the order of the
commissioner. Further this decision was challenged in front of a division bench consisting of Justice Asok
Kumar Ganguly and Justice Gyan Sudha Mishra which held that when complaint under section 18 is made
the Commissioner can not direct an order to release the information.
Through this judgement the RTI applicant will have to file a separate appeal for the same matter to obtain
the required information. Also, if the Public Information officer doesn’t accept the application then the
information seeker would have to first file a complain about it to the commission. Even after this the Public
Information Officer can deny to present the required information. The advancement in the RTI Act has put
a load on the RTI applicant and the Commission as well.

6. R.K. Jain Vs Union of India14

FACTS: Mr. R.K. Jain, the appellant, applied for the copies of all note sheets and some other similar pages
of a file of related to Ms. Jyoti Bala’sundaram through the RTI in 2009. The Central Public Information
Officer refused to provide the requested information on the ground that the information sought or the file
requested contained analysis of Ms. Jyoti Bala’Sundaram’s Annual Confidential Report (ACR) which was
personal information and disclosure of such an information was exempted u/s 8(1)(j) of the Right To
Information Act. Likewise several appeals were made by the appellate to the commission and the concerned
authority which were rejected and denied on the basis that the personal information of Jyoti was not of

14
(1993) 3 SCR 802
 public interest. Later on, Mr. Jain appealed to Delhi High Court and then to a Division Bench in same court
which rejected Mr. Jain ‘s application and reiterated that an officer’s ACR can not be disclosed to anyone
other than the Officer concerned. The appeal then reached The Supreme Court15.
ISSUES: Should the information be disclosed when it is concerned with the inspection of some confidential
remarks against ‘integrity’ of a tribunal member and should the personal information be disclosed if
exemption is claimed based on section 8(1)(j) of the act.
HELD: In this case the Supreme Court strictly relied upon its previous Judgement in Girish Ramchandra
Deshpande v. Central Information Commissioner and ors. in which it was held by the Court that
information that related to sanctions and charges and other penalties that were imposed on an employee
were of such nature that disclosure of which had no relation with any public interest or activity will only
cause unjustified invasion of privacy. Now, when that case was used as a precedent in this case then the
appeal of Mr. Jain was dismissed and the findings of the Division Bence of Delhi High Court were
reaffirmed.16
ANALYSIS: Findings in this case cleared the point that the privacy of a public officer heavily outweighed
the RTI regarding the Public Officer, Jyoti. Also, through this case the court cleared the point that the
determination of the closure of such type of information would qualify as a favour to larger interest of
public only within the discretion of the Information Commissioners.

CONCLUSION
The above examination shows that in just two cases did the Supreme Court decide for a RTI Applicant. In
the CBSE the Court has made very solid remarks practically denouncing the utilization of RTI by residents.
Residents anticipate that the Supreme Court should be sentinel on the qui vive guarding and extending their
crucial rights. A portion of the announcements cited above appear to be at incredible fluctuation with what
the Supreme Court said in S.P.Gupta (AIR 1982 SC 149) "… The idea of an open government is the
immediate radiation from the privilege to realize which is by all accounts certain morally justified of free
discourse and articulation ensured under Article 19(1)(a). In this manner, revelation of data as to the
working of Government must be the standard what's more, mystery an exemption defended just where the
strictest prerequisite of open intrigue so requests. The methodology of the court must be to weaken the zone
of mystery however much as could be expected reliably with the prerequisite of open enthusiasm,
remembering constantly that divulgence additionally serves a significant part of open intrigue… " It is hard
to accept that the Supreme Court which prior held that disavowal of data ought to be a 'special case
defended just where the strictest necessities of open intrigue requests' (which are presently secured under
Section 8) is presently supporting disavowal of data except if an open intrigue is appeared! While the law
15
https://globalfreedomofexpression.columbia.edu/cases/r-k-jain-v-union-india-anr/
16
https://dsscic.nic.in/files/upload_decision/CIC-NINCL-A-2017-193461-BJ--.pdf
 obviously expresses that a resident necessities to give no explanations behind looking for data, the peak
Court's decisions propose that there should be a certifiable explanation behind acquiring data. It is likewise
important that apparently with the Girish Deshpande judgment, Section 8 (1) (j) has been deciphered in a
way not in consonance with its words. In spite of the fact that it has no proportion or thinking, it is turning
into the standard for dismissing data. Hence, this research concludes that Right to Information is a essential
part of the human life in this modern period of life on democratic governance. And in a country like India
RTI acts as an assurance of widespread participation of citizens regarding the public affairs in a civil
society.
“If liberty and equality, as is thought by some are chiefly to be found in democracy, they will be the best
attained when all persons alike share in the government to the utmost”.17

17
Aristotle