CENTRAL INFORMATION COMMISSION
Sudha Rani Relangi, Information Commissioner
Dheeraj Kumar Singh – Appellant
Versus
CPIO, Indian Institute Of Technology, Madras – Respondent
CIC/IITMD/A/2025/634151 | CIC/IITJP/A/2025/634132 | CIC/IITGO/A/2025/634131 | CIC/IITKP/A/2025/636407

Sensitive personal and identifiable information of deceased individuals is protected from disclosure under the right to privacy. Disclosure cannot be compelled unless a clear, overriding public interest is established and the information is not otherwise protected under contemporary data privacy frameworks.

Headnote:(A) Right to Information Act, 2005 - Sections 8(1)(j), 4, 19(5), 25(5) - Digital Personal Data Protection Act, 2023 - Section 44(3) - Mental Healthcare Act, 2017 - Section 23 - Disclosure of sensitive personal information of deceased students - Whether personal attributes like age, caste, and identity are exempt from disclosure - Information regarding suicides qualifies as personal data - Disclosure of such granular details constitutes an unwarranted invasion of privacy - Right to privacy is a fundamental right - Larger public interest not demonstrated by applicant to override privacy protections - Statutory obligation to withhold personal data affirmed. (Paras 18, 19, 23, 26, 28, 29, 30)

(B) Administrative Law - Transparency versus Privacy - Public authorities are not required to generate information or disclose third-party personal data under the guise of academic research where such disclosure lacks sufficient public interest nexus - Proactive disclosure of systemic mitigation measures is preferred over individual granular data release. (Paras 28, 29, 30)

Facts of the case:
An alumnus filed multiple requests seeking granular, personally identifiable information—including name, age, gender, caste, native state, and specific location—of students who died by suicide at technical institutes over a two-decade period. The requests were denied by the public authorities on the grounds that the information is personal in nature, exempt under Section 8(1)(j) of the Act, and its disclosure would violate the privacy rights of the deceased and their families. The applicant contended that the data was necessary for mental health advocacy and counseling research.

Findings of Court:
The Commission observed that while the number of incidents and aggregate data regarding the incidents had been provided to the applicant, the request for granular, identifiable personal attributes cannot be entertained. The Commission clarified that disclosure of sensitive personal data, such as caste and age of deceased individuals, has no clear nexus to larger public interest and invites risks of re-identification. The Commission recommended that the authorities proactively maintain and publish information regarding the constitution of student welfare committees and mitigation strategies to reduce the burden of individual information requests.

Issues: Whether requests for granular, personally identifiable data of deceased individuals regarding sensitive events are exempt from disclosure under privacy protections, and whether such disclosure is justified by a purported public interest.

Ratio Decidendi: The release of sensitive, personally identifiable information of deceased individuals constitutes an unwarranted invasion of privacy. In the absence of a demonstrably overriding public interest, such information is protected by the spirit of the legislation and privacy jurisprudence, especially when anonymous aggregate data serves the stated objective of research or policy analysis.

Result: Appeals disposed of; recommendations issued for proactive institutional disclosure.