Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(CIC) 6897

CENTRAL INFORMATION COMMISSION
Sanjeev Kumar Jindal, Information Commissioner
Sanjeev Kumar Bhardwaj – Appellant
Versus
Cpio – Respondent
CIC/DMRCP/A/2024/652971

Advocates:
For the Appellants/Petitioners: Sanjeev Kumar Bhardwaj
For the Respondents: Sunil Singh Rathi, Neha Agarawal

The RTI Act cannot be utilized as a tool for personal grievance redressal or to compel disciplinary action; furthermore, service records and disciplinary details of third-party employees constitute personal information exempt from disclosure under Section 8(1)(j) unless a larger public interest is established.

Headnote:(A) Right to Information Act, 2005 - Sections 2(f), 6, 8(1)(j), 10 and 19(5) - Public authority - Information regarding disciplinary proceedings - Disclosure - Appellant sought details of disciplinary/departmental action taken against DMRC employees involved in private criminal dispute - Respondents claimed matter private and information exempt under Section 8(1)(j) - Commission observed RTI Act not tool for grievance redressal - Personal information of employees cannot be disclosed without larger public interest. (Paras 6, 8, 10)

Facts of the case:
The appellant filed an RTI application seeking information about disciplinary and legal actions taken by the public authority against two of its employees who were facing a criminal case (FIR No. 605/2023) initiated by the appellant and his wife due to a neighborhood dispute. The appellant questioned why disciplinary action had not been taken and requested access to service records and departmental reports. The public authority denied the disclosure, citing that the matter was a private dispute, information was not available in material form, and the data was personal information protected under Section 8(1)(j).

Findings of Court:
The Commission noted that the respondent provided a point-wise reply based on available records, clarifying that the private dispute did not warrant departmental intervention. The Commission held that the RTI Act cannot be used as a grievance redressal mechanism to compel disciplinary action against public employees and upheld the denial of information which constitutes personal data.

Issues: Whether the appellant is entitled to access service records and disciplinary details of third-party employees concerning a private criminal dispute, and whether the respondent correctly invoked exemptions under the RTI Act.

Ratio Decidendi: Information regarding disciplinary proceedings and service records of third-party employees is personal in nature and exempt under Section 8(1)(j) of the RTI Act, 2005, absent larger public interest. Furthermore, the RTI Act does not provide a mechanism for the redressal of private grievances.

Result: Appeal dismissed.

Relevant facts emerging from Second Appeal:

RTI application filed on : 12.06.2024

CPIO replied on : 11.07.2024

First appeal filed on : 07.08.2024

First Appellate Authority’s order : 23.09.2024; 24.09.2024

Second Appeal dated : 03.12.2024

Information sought:

1. The Appellant filed an RTI application on 12.06.2024 seeking the following information :

“XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX

INFORMATION(S) REQUIRED UNDER SECTION 6 OF THE R.T.I. ACT 2005

Information(s) which are required U/S 6 of R.T.I. Act, 2005 which falls under the purview/jurisdiction of the D.M.R.C. Ltd., moreover, which comes under section 2(f) of R.T.I. Act 2005 are as follow para wise :-

1) Has any sort of Disciplinary Action(s), which comes under the purview/jurisdiction of D.M.R.C. LTD. as per the D.M.R.C. LTD. SERVICE RULES AND REGULATIONS i.e. CONDUCT, DISCIPLINE AND APPEAL RULES CHAPTER- B PART II - CONDUCT AND PART III - DISCIPLINE etc., been taken/initiated/recommended by the D.M.R.C. LTD./concerned assigned department(s)/enquiry officer(s) of its against above mentioned both the employees of D.M.R.C. Ltd. namely Mr. Akash Kumar Assistant Section Engineer and Mrs. Swati Aggarwal Sr. Station Controller/Train Operator both the employees/accused persons are directly involved in a Criminal Case/F.I.R No. 605/2023 u/s 323/354/509/506/341/34 I.P.C. dated 18/08/2023 P.S. Begum Pur Delhi which is pending in the Hon'ble Court Of M.M. Rohini Courts Delhi against both of them and against other involved co-accused persons? Please provide the complete information/details/action taken report regarding it.

2) Has any sort of Departmental Enquiry(s), which comes under the purview/jurisdiction of D.M.R.C. LTD. as per D.M.R.C. LTD. SERVICE RULES AND REGULATIONS i.e. CONDUCT, DISCIPLINE AND APPEAL RULES CHAPTER- B PART II - CONDUCT AND PART III -DISCIPLINE etc., been initiated/recommended/conducted by the D.M.R.C. LTD./concerned assigned department(s)/enquiry officer(s) of its against above mentioned both the employees of D.M.R.C. LTD. namely Mr. Akash Kumar Assistant Section Engineer and Mrs. Swati Aggarwal Sr. Station Controller/Train Operator both are directly involved in the above mentioned CRIMINAL CASE/F.I.R. and this CR. CASE is pending against them?

Please provide the complete information/details/ action taken report regarding it.

3) Has public conduct of above mentioned both the public servants/employees of the D.M.R.C. LTD., namely Mr. Akash Kumar Assistant Section Engineer and Mrs. Swati Aggarwal Sr. Station Controller/Train Operator, i.e. their direct involvement in the above mentioned Criminal Case/F.I.R. as well as their involvement in moral turpitude, anti-social activists etc. which mentioned in details in Complainant(wife of R.T.I. Applicant)/Mr. Jyoti Bhardwaj's earlier complaints to the D.M.R.C. Ltd. against above mentioned both the employees of its vide written complaint dated 16/01/2024 along with (Documentary and D.V.D. evidences), 10/06/2024 etc., been mentioned in their respective Service Book which comes under the purview/jurisdiction of D.M.R.C. LTD. by the D.M.R.C. LTD./concerned assigned department(s)/enquiry officer(s) of its?

Please provide the complete information/details/action taken report regarding it.

4) Have above mentioned both the employees of the D.M.R.C. LTD. Namely Mr. Akash Kumar Assistant Section Engineer and Mrs. Swati Aggarwal Sr. Station Controller/Train Operator timely informed the D.M.R.C. LTD./concerned official(s) of its, in full details that above mentioned F.I.R. No. 605/2023 Dated 18/08/2023 registered against them and this Criminal Case/F.I.R. pending against them in the Hon'ble Court? Please provide the complete information/details regarding it.

5) Please provide the complete information/details that as and when above mentioned both the employees of D.M.R.C. LTD. informed the D.M.R.C. LTD./concerned official(s) of its about their involvement in the above mentioned Criminal Case/F.I.R. as well as

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2026 Supreme(Online)(CIC) 6897

CENTRAL INFORMATION COMMISSIONSanjeev Kumar Jindal, Information CommissionerSanjeev Kumar Bhardwaj – AppellantVersusCpio – RespondentCIC/DMRCP/A/2024/652971

CENTRAL INFORMATION COMMISSION
Sanjeev Kumar Jindal, Information Commissioner
Sanjeev Kumar Bhardwaj – Appellant
Versus
Cpio – Respondent
CIC/DMRCP/A/2024/652971