Madras High Court: Routine Admin Info Cannot Be Withheld Under RTI

The Madras High Court has ruled that routine administrative information cannot be withheld under the Right to Information (RTI) Act unless it falls under specific exemptions. The court directed the high court registry to disclose details about its Party-In-Person Committee, while allowing only the withholding of conduct details of committee members.

Justice M Dhandapani, on July 27, heard a writ petition filed by the high court registrar general. The petition challenged a 2023 order of the Tamil Nadu Information Commission that had directed the registry to furnish information sought by an RTI applicant. The information related to the Party-in-Person Committee and the administrative committee of the high court.

In his ruling, Justice Dhandapani stated: “So long as there is no conflicting interest and the security and safety is not jeopardized, the citizens are to be provided with all the information that are available at the disposal of the public… The information cannot be denied to the Parliament or a State Legislature and, therefore, any citizen is entitled to get the said information under the provisions of the RTI Act.”

The ruling clarifies that while confidential records such as vigilance inquiries and disciplinary matters may be exempt under Section 8 of the RTI Act, routine administrative information about a public authority’s functioning cannot generally be withheld. The court emphasised that exemptions must be narrowly construed.

The dispute originated from an RTI application filed by Akbar Ahamed on July 28, 2021. He sought details about the High Court of Madras (Conduct of Proceedings by Party-in-Person) Rules, 2019, including names and designations of committee members, their educational qualifications, experience, pay scale, and the functions of the administrative committee. He also sought conduct details of committee members.

The public information officer rejected the application, citing an earlier division bench judgment. The first appellate authority upheld the rejection. Ahamed then approached the Tamil Nadu Information Commission, which on October 18, 2023, directed the registry to provide the information. The registrar general then filed the present writ petition.

The registry argued that the information pertained to internal administration and was exempt under Section 8(1)(e) and (j) of the RTI Act. It relied on an earlier division bench ruling that had upheld non-disclosure of vigilance-related information about judicial officers.

Justice Dhandapani found this reliance misplaced. The earlier judgment dealt with vigilance inquiries, disciplinary proceedings, and personal information that could prejudice institutional functioning and invade privacy. In contrast, the present case involved details of committee composition, qualifications, experience, pay, and functions. “The information sought for by the 2nd respondent would by no stretch fall within the exemptions prescribed under Section 8 of the RTI Act,” the court held.

The court noted that several details sought, such as qualifications and experience, were already available on the high court’s website or could be compiled without disproportionate effort. It directed the registry to disclose all information except the conduct details, which were not available with the registry.

This judgment reinforces the principle of transparency in public administration. The RTI Act, enacted to promote openness and accountability, does not permit public authorities to withhold routine information by citing vague exemptions. The decision is likely to have implications for how public bodies across India handle similar requests.