Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(CIC) 4962

CENTRAL INFORMATION COMMISSION
Sudha Rani Relangi, Information Commissioner
Madhuresh Kumar Jha – Appellant
Versus
CPIO Indian Institute Of Technology – Respondent
CIC/IITMN/A/2025/613569

Advocates:
For the Appellants/Petitioners:
For the Respondents: Parminder Gill

While question papers and answer keys where the question bank is limited may be exempted from disclosure to maintain examination integrity, the marks of selected candidates in public recruitment must be disclosed to ensure transparency, as such details are not protected under Section 8(1)(j) of the RTI Act.

Headnote:(A) Right to Information Act, 2005 - Sections 8(1)(j) and 10 - Recruitment process - Disclosure of question papers and answer keys - Appellant sought question papers, answer keys, OMR sheets, marks of shortlisted candidates, and cutoff marks - CPIO denied questions and answer keys citing limited question bank and potential harm to competitive position; denied marks of other candidates under Section 8(1)(j) - Commission upheld denial of question papers and keys following established precedents that disclosure of limited question banks undermines selection efficacy - Commission ordered disclosure of marks of selected candidates under Section 10, holding that transparency in public recruitment overrides privacy claims under Section 8(1)(j) once the selection process is complete. (Paras 10-16)

Facts of the case:
The appellant sought information regarding a recruitment process for the post of Assistant Registrar at an academic institution. The CPIO provided some information but refused to disclose the question paper, answer keys, and the marks of other candidates. The First Appellate Authority upheld the CPIO's stance regarding the documents but directed disclosure of category-wise cutoff marks.

Findings of Court:
The Commission affirmed the denial of question papers and answer keys, noting that disclosure would compromise the integrity of the examination. However, it reversed the denial of marks obtained by selected candidates, ruling that transparency in public recruitment is mandatory and such details cannot be shielded as personal information once the selection process concludes.

Issues: Whether the disclosure of question papers and answer keys for a limited question bank can be compelled under the RTI Act, and whether marks of selected candidates in public recruitment fall under the privacy exemption of Section 8(1)(j).

Ratio Decidendi: Expert-led academic evaluation processes are generally immune from interference; however, public accountability mandates that marks of successful candidates in a public selection process be disclosed to ensure transparency, as such information does not constitute 'personal information' unrelated to public activity.

Result: Appeal partially allowed.

Table of Content
1. procedural background and denial of information under rti act. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7)
2. exemption from disclosure of question papers and answer keys in competitive exams. (Para 8 , 9 , 10 , 11 , 12 , 13 , 14)
3. disclosure of final candidate marks as a matter of transparency in public interest. (Para 15 , 16)

Relevant facts emerging from appeal:

RTI application filed on : 29.01.2025

CPIO replied on : 27.02.2025

First appeal filed on : 28.02.2025

First Appellate Authority’s order : 17.03.2025

2nd Appeal dated : 20.03.2025

Information sought:

1. The Appellant filed an RTI application dated 29.01.2025 seeking the following information:

“With reference to the advertisement for the post of Assistant Registrar vide Advt. No. IIT Mandi/Recruit./NTS/2024/04 Dated: 30.08.2024 and subsequent selection process held on 27.01.2025 wherein undersigned appeared with Application ID: IITMNDNT11751, please provide the following information/records under RTI Act, 2005:

1. Copy of question paper for the written test held on 27.01.2025 for the post of Assistant Registrar.

2. Copy of Answer keys for the above test.

3. Copy of OMR sheet of undersigned appeared in the test with Application ID: IITMNDNT11751.

4. Marks of the candidates in written test who were shortlisted for interview for the post of Assistant Registrar.

5. Criteria of shortlisting/ cut off Marks for interview for the post of Assistant Registrar.”

2. The CPIO furnished a reply to the Appellant on 27.02.2025 stating as under:

“Reply :- the desired information is attached herewith as Annexure A and Annexure B

Annexure A

Reply 1 & 2:

The question papers for the post of Assistant Registrar are very limited in nature. The disclosure of the same with the answer key would harm the competitive position of the candidates appearing in the examination. Therefore, the same cannot be disclosed under the RTI Act, 2005.

Reply 3:

For the information sought please refer the Annexure B.

Reply 4:

Information sought is question/query in nature, hence cannot be provided under the RTI Act, 2005. Further, Personal information of candidates cannot be shared as per section 8(1)(j) of RTI Act.

Reply 5:

Information sought is question/query in nature, hence cannot be provided under the RTI Act, 2005.”

3. Aggrieved by the decision of the CPIO, the Appellant filed a First Appeal dated 28.02.2025. The FAA vide its order dated 17.03.2025, stating as under-

“1. The undersigned perused the RTI application dated 29.01.2025, response by the CPIO dated 27.02.2025, together with the present online appeal dated 28.02.2025. Further, inputs from the concerned section were also taken in this regard.

2. After considering these on merits, it is observed that the response to the RTI application given by the CPIO is in order. Further, on point number 5, CPIO are advised to provide the cutoff marks of various categories to the written examination for the post of Assistant Registrar.

3. Accordingly, present appeal is disposed off.”

CPIO reply of Point no.5 on the order of FAA

Reply 5:

The cut off marks in written examination (category wise) for the post of Assistant Registrar (IITMandi/Recuirt./NTS/2024/04) are as under: -

UR :33.00.

OBC: 28.00.

SC: 24.00”

4. Challenging the FAA’s order, Appellant is before the Commission with the instant Second Appeal against point Nos. 1, 2 and 4 of RTI application in question.

Relevant Facts emerged during Hearing:

The following were present:-

Appellant: Not present.

Respondent: Shri Parminder Gill, DR/CPIO present through video conference.

5. Written statement filed by the Appellant as well as the CPIO are taken on record.

6. The Appellant through his written sought exemption from participating in the hearing proceedings due to personal reasons and prayed the Commission that his Second Appeal may be decided on merits based on the material placed on record.

7. CPIO relying on his written statement stated that on point No. 1 and 2 of the RTI application of the appell

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2026 Supreme(Online)(CIC) 4962

CENTRAL INFORMATION COMMISSIONSudha Rani Relangi, Information CommissionerMadhuresh Kumar Jha – AppellantVersusCPIO Indian Institute Of Technology – RespondentCIC/IITMN/A/2025/613569

CENTRAL INFORMATION COMMISSION
Sudha Rani Relangi, Information Commissioner
Madhuresh Kumar Jha – Appellant
Versus
CPIO Indian Institute Of Technology – Respondent
CIC/IITMN/A/2025/613569