Delhi High Court upholds privacy over RTI in Smriti Irani degree case

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The Delhi High Court has ruled that personal academic records, including those of public figures, remain protected under the Right to Information (RTI) Act unless an overriding public interest is clearly established. The judgment came in the context of petitions related to the disclosure of educational qualifications of former Union Minister Smriti Irani and Prime Minister Narendra Modi.

Justice Sachin Datta, while pronouncing the order, emphasized that Section 8(3) of the RTI Act does not dilute the protection afforded under Section 8(1)(j), which exempts personal information from disclosure unless it serves a demonstrable public interest. The Court clarified that the fundamental right to privacy, as affirmed in K.S. Puttaswamy v. Union of India, extends to educational credentials, making their disclosure subject to strict scrutiny.

The Court set aside the directives issued by the Central Information Commission (CIC), which had earlier instructed universities and other authorities to furnish degree-related information of the two political leaders. These directions, the Court noted, went beyond the statutory mandate and infringed upon the individuals’ right to privacy.

Justice Datta further observed that even if certain details have previously been made public, this does not override the statutory safeguards under the RTI framework. The judgment underlined that the RTI Act is not an absolute instrument; it mandates a careful balance between transparency and privacy. According to the Court, the petitions failed to demonstrate any compelling public interest that could justify breaching this privacy shield, especially since academic qualifications are not a constitutional or statutory prerequisite for holding public office.

This ruling reinforces the jurisprudence that transparency must coexist with the right to privacy and reaffirms the principle that information-seeking rights under RTI cannot be weaponized to invade personal domains without adequate justification, thereby



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