Delhi HC: Privacy Cannot Be Compromised for RTI in Smriti Irani Degree Case

The Delhi High Court has held that personal academic records, even of public figures, are protected under the Right to Information (RTI) Act unless there is a clear and overriding public interest in disclosing them.

The ruling came in response to petitions seeking details of the educational qualifications of former Union Minister Smriti Irani and Prime Minister Narendra Modi.

Justice Sachin Datta, while delivering the judgment, clarified that Section 8(3) of the RTI Act cannot weaken the safeguard under Section 8(1)(j), which protects personal information from disclosure unless it serves a strong public interest. Referring to the landmark K.S. Puttaswamy v. Union of India case, the Court reiterated that the right to privacy extends to educational credentials as well.

The Court also set aside the orders of the Central Information Commission (CIC), which had directed universities and other authorities to provide degree-related information of the two leaders. The Court found these directions to be beyond the RTI’s mandate and an infringement of the individuals’ right to privacy.

Justice Datta further explained that even if certain details have already appeared in the public domain, this does not dilute the protection granted under the RTI framework. The Court emphasised that RTI is not absolute; it requires a careful balance between transparency and privacy. Since the petitions could not show any compelling public interest, the Court held that academic qualifications are private in nature, particularly because they are not a legal requirement for holding public office.

This judgment reinforces the principle that while transparency is essential in a democracy, it cannot come at the cost of an individual’s right to privacy. The Court made it clear that RTI cannot be used as a tool to intrude into personal matters without strong justification.