Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(CIC) 1291

CENTRAL INFORMATION COMMISSION
Sudha Rani Relangi, Information Commissioner
Arvind Bhatt – Appellant
Versus
CPIO, Dr. Harisingh Gaur University, Sagar – Respondent
CIC/DHGVV/A/2024/626568|CIC/DHGVV/A/2024/626567|CIC/DHGVV/A/2024/626566|CIC/DHGVV/A/2024/626565|CIC/DHGVV/A/2024/626561|CIC/DHGVV/A/2024/626560|CIC/DHGVV/A/2024/626558|CIC/DHGVV/A/2024/626559|CIC/DHGVV/A/2024/626556|CIC/DHGVV/A/2024/626552|CIC/DHGVV/A/2024/626550|CIC/DHGVV/A/2024/626547|CIC/DHGVV/A/2024/626549

Advocates:
For the Appellants/Petitioners:
For the Respondents: Brij Bhushan Singh, Rajneesh Jain

Candidate application forms with personal details exempt from disclosure under RTI Section 8(1)(j) absent public interest; public authorities must proactively disclose recruitment details on websites.

Headnote:(A) Right to Information Act, 2005 - Sections 2(f), 4(1), 8(1)(e), 8(1)(j), 11, 19(1), 20(1), 25(5) - Digital Personal Data Protection Act, 2023 - Section 44(3) - Disclosure of application forms with supporting documents submitted by recruitment candidates - Such forms contain personal information of third parties exempt under Section 8(1)(j); list of candidates called for interview provided - No larger public interest established for disclosure warranting invasion of privacy - Blanket denial without reasoned order improper but exemption upheld post amendment removing public interest override (Paras 67-72)

(B) Right to Information Act, 2005 - Section 4(1) - Suo motu disclosure - Public authorities obligated to proactively disclose recruitment details including advertisements, selected candidates lists, qualifications on official websites to promote transparency and reduce RTI burden - Recommendations issued to ensure compliance (Paras 73-75)

Facts of the case:
Multiple second appeals clubbed for disposal concerning RTI applications seeking recruitment process details, candidate lists, application forms, marksheets, and compliance records from university. CPIO denied copies of applications citing personal information exemption; FAA directed partial disclosure. Appeals challenged denial and alleged non-transparency.

Findings of Court:
Application forms and supporting documents exempt as personal information; list of candidates already provided. Public authority directed to implement proactive disclosures on website with compliance report within six weeks.

Issues: (1) Disclosability of third-party candidate application forms under personal information exemption; (2) Compliance with mandatory suo motu disclosure norms for recruitment processes.

Ratio Decidendi: Personal records in candidate applications qualify as exempt personal information absent larger public interest; appellate intervention unwarranted where lists provided. Proactive disclosure under Section 4(1) mandatory to foster transparency in public employment.

Result: Appeals partly allowed; no further intervention on personal information; recommendations for suo motu disclosures issued.

Table of Content
1. rti timelines and cpio/faa responses summarized (Para 1 , 2 , 3)

Information sought:

1. The Appellant filed an RTI application dated 18.01.2024 seeking the following information:

2. Having not received any response from the CPIO, the appellant filed a First Appeal dated 19.02.2024.

3. Meanwhile, the CPIO furnished a reply to the Appellant on 19.03.2024 stating as under:

“1. The applications submitted by the candidates including copies of marks sheet are the personal information and no larger public interest is involved in its disclosure and as such it is exempted from disclosure under Section 8 (1)(j) of RTI, Act 2005.

2. Information pertains to third party and no larger public interest involves in it and as such it is exempted from disclosure under Section 11 of RTI Act, 2005.

3. Please refer reply at serial no. 02. 4. Please refer reply at serial no. 02. 5. Please refer reply at serial no. 02.

6. The applications submitted by the candidates including copies of marks sheet are the personal information and no larger public interest is involved in its disclosure and as such it is exempted from disclosure under Section 8 (1)(j) of RTI, Act 2005.

4. The FAA vide its order dated 22.03.2024 disposed of the First Appeal directing the CPIO to furnish relevant information at point No. 3 of RTI application within 15 days.

2. CIC/DHGVV/A/2024/626567

Relevant facts emerging from appeal:

RTI application filed on : 18.01.2024

CPIO replied on : 19.03.2024

First appeal filed on : 19.02.2024

First Appellate Authority’s order : 22.03.2024

2nd Appeal/Complaint dated : 19.06.2024

Information sought:

5. The Appellant filed an RTI application dated 18.01.2024 seeking the following information:

6. Having not received any response from the CPIO, the appellant filed a First Appeal dated 19.02.2024.

7. Meanwhile, the CPIO furnished a reply to the Appellant on 19.03.2024 stating as under:

2. Information pertains to third party and no larger public interest involves in it and as such it is exempted from disclosure under Section 11 of RTI Act, 2005.

3. Please refer reply at serial no. 02. 4. Please refer reply at serial no. 02. 5. Please refer reply at serial no. 02.

8. FAA vide its order dated 22.03.2024 disposed of the First Appeal directing the CPIO to furnish relevant information at point No. 3 of RTI application within 15 days.

3. CIC/DHGVV/A/2024/626566

Relevant facts emerging from appeal:

RTI application filed on : 18.01.2024

CPIO replied on : 19.03.2024

First appeal filed on : 19.02.2024

First Appellate Authority’s order : 22.03.2024

2nd Appeal/Complaint dated : 19.06.2024

Information sought:

9. The Appellant filed an RTI application dated 18.01.2024 seeking the following information:

10. Having not received any response from the CPIO, the appellant filed a First Appeal dated 19.02.2024.

11. Meanwhile, the CPIO furnished a reply to the Appellant on 19.03.2024 stating as under:

2. Information pertains to third party and no larger public interest involves in it and as such it is exempted from disclosure under Section 11 of RTI Act, 2005.

3. Please refer reply at serial no. 02. 4. Please refer reply at serial no. 02. 5. Please refer reply at serial no. 02.

6. The applications submitted by the candidates including copies of

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