The RTI Act permits withholding information that compromises third-party privacy and fiduciary confidentiality, affirming that internal documents are exempt from disclosure under specific provisions.

Information sought:

1. The Appellant filed an RTI application dated 01.01.2024 (offline) seeking the following information:

“Agency code No. 05942611-Sutram Suresh-Documents showing the approval of the Disciplinary Authority obtained on the request dated 11.12.2023 made by the presenting officer, Smt Latha B.C. A.O.(SSS), LIC of India, Bangalore-DO-1, for providing letter Ref. DO1/Mktg. dated 12.03.2018 and my reply dated 28.06.2018.”

2. The CPIO furnished a reply to the Appellant on 10.01.2024 stating as under:

“The information sought by you regarding the documents showing the approval of the Disciplinary Authority obtained on the request dated 11.12.2023, is in nature of internal documents/correspondence and held by the Public Authority in fiduciary capacity and also disclosure of such information would endanger the life or physical safety of the third party and would also cause unwarranted invasion of their privacy. Hence we are unable to provide the information sought by you under Section 8 (1) (e), 8 (1) (j) and 8 (1) (g) of the RTI Act.

References:

CIC/LICOI/A/2021/124049- Sri Sunder Lal Vs CPIO, LIC, Karnal : The Commission observes that the information sought by the applicant is an internal document/correspondence and held by the public authority in fiduciary capacity. Therefore the same is exempted from disclosure under Sec 8 (1) (e) of the RTI Act. CIC/LICOI/A/2021/102332- Sri Ravinder Chopra Vs CPIO, LIC, Delhi : The information sought are personal information related to third party which cannot be provided to the applicant and the disclosure of such information would endanger the life or physical safety of the their employee and would cause unwarranted invasion of their privacy. Therefore, the information sought cannot be provided as per Sec 8 (1) (j) & 8 (1) (g) of RTI Act.”

3. Being dissatisfied, the Appellant filed a First Appeal dated 08.02.2025. The FAA vide its order dated 27.02.2024, held as under:

“The copies of letter Ref No: DO1/Mktg., dated 12.03.2018 and your reply letter dated 28.06.2018 were already provided to you during the disciplinary proceedings by the Presenting Officer vide Registered post dated 13.12.2023. On revisiting the records, it is informed that the approval for providing the above documents was accorded by the Senior Divisional Manager who is the Disciplinary Authority in this matter. The copy of the approval letter is an internal document not meant for outside circulation and hence cannot be provided.

It is further clarified that the Disciplinary Authority is the First Appellate Authority by virtue of his designation hence there is no violation of any principles of natural justice...”

4. Feeling aggrieved and dissatisfied, Appellant approached the Commission with the instant Second Appeal.

Relevant Facts emerged during Hearing:

The following were present:-

Appellant: Present through video conference.

Respondent: Shri C R Aravind, Manager/CPIO along with Shri Bhaskar, Manager (Sales) and Shri Arvind Kumar, A.O. (Marketing) present through video conference.

5. Proof of having served a copy of Second Appeal on Respondent while filing the same in CIC on 20.05.2024 is not available on record. The parties confirmed non-service.

6. The Respondent submitted that their FAA, Shri P N Jha, Sr. Divisional Manager has filed a written submission dated 12.11.2025 enumerating the detailed facts of this case. A copy of which was already sent to the Appellant. He prayed the Bench to take it on record. Prayer allowed. Relevant extracts of the written submission are reproduced below for ready reference:

“…OUR WRITTEN SUBMISSION TO THE SECOND APPEAL:-

In the RTI stage since the applicant sought info