Limitations on Scope of Right to Information in reference to

Section 8 of RTI Act 2005

Submitted to: Dr. Manoj Kumar Submitted by: Shreya Verma

Assistant Professor Law En. Id- 160101144
Semester- IX
Subject: Right to Information

DR. RAM MANOHAR LOHIYA NATIONAL LAW UNIVERSITY, LUCKNOW

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Acknowledgement

Firstly, I would like to thank respected Dr. Aparna Singh for giving me such an excellent
opportunity to show my skills, through my project and enhance my knowledge on this topic. I
wish to acknowledge that in completing this project I had full support of my library staff. This
project would not have been completed without the help of my university’s library Dr. Madhu
Limaye library that had various quality books on the chosen topic and the university’s internet
facility that helped me in making my research a success.

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Table of Contents
Acknowledgement...........................................................................................................................2

ABSTRACT....................................................................................................................................4

INTRODUCTION...........................................................................................................................4

RTI; a fundamental right.............................................................................................................5

RTI ACT......................................................................................................................................5

Brief History................................................................................................................................6

Impact of RTI Laws.....................................................................................................................7

EXEMPTIONS UNDER RTI ACT 2005........................................................................................8

RTI CONSTRICTED....................................................................................................................11

Conclusion.....................................................................................................................................18

Bibliography..................................................................................................................................19

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ABSTRACT

Section 8 of the RTI Act, 2005 provides for exemptions to RTI. This paper is dedicated to study
exemptions and rejections u/s 8. The aim of the paper is to find out, whether the exemptions
under section 8 of the Act are used by officers to deflect their duties, and cause loss to larger
public, or not.

INTRODUCTION

A healthy democracy requires public participation in the formulation and administration of

government policy. Full information about policy proposals and debate over alternatives ensure
popular consent. Public examination of ongoing programs ensures the government's
accountability1. RTI is a tool for gaining transparency in administration as well as trust of the
public. It helps in creating a virtuous cycle for the governing authority as well as people who are
governed, as increasing transparency will consequently increase faith of the public.

RTI stands for Right to Information. RTI means that citizens can request for information from
state or central government departments and offices. And such request should be processed in a
timely way as mandated by the RTI Act.

Restrictions on the free flow of information, especially between government and citizen, has
resulted not only in eroding the democratic principles enshrined in the Indian Constitution but
has resulted in the failure of government policies and development schemes for bettering the lot
of the poor. Denial of information has perpetuated the political, social and economic exclusion of
millions; aided in the illegitimate retention and abuse of power by select segments of society;
facilitated widespread corruption and impeded the fight against poverty eradication. With the
lack of access to information, people are unaware of the developments schemes and are
completely unequipped to engage in informed participation in their own development even if
given a chance. Therefore, decades of development have been lost through decision making
uninformed by the realities of those without a veritable voice. The concept of human

1
Morton H. Halperin ,,&” Daniel N. Hoffman, Secrecy and The Right to Know, 40 LAW AND CONTEMPORARY
PROBLEMS  132-165, 132 (Summer 1976).

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development is directly linked to human rights. A rights-based approach demands participation
in governance and development, which guaranteed access to information can provide.

RTI; a fundamental right

The expression “freedom of speech and expression” in Article 19(1)(a) has been held to include
the right to acquire information and disseminate the same.

Genesis of RTI law started in 1986, through judgement of Supreme Court in L.K. Koolwal v
State of Rajasthan and Ors. case, in which it directed that freedom of speech and expression
provided under Article 19 of the Constitution clearly implies Right to Information, as without
information the freedom of speech and expression cannot be fully used by the citizens2.

In PUCL case, The Supreme Court dealt with this aspect of freedom elaborately. The right of
citizens to obtain information on matters related to public act flows from the Fundamental Right
enshrined in Article 19(1)(a).3

People cannot speak or express themselves unless they know. Therefore, right to information is
embedded in article 19. India is a democracy. People are the masters. Therefore, the masters
have a right to know how the governments, meant to serve them, are functioning. Further, every
citizen pays taxes. Even a beggar on the street pays tax (in the form of sales tax, excise duty etc.)
when he buys a piece of soap from the market. The citizens therefore, have a right to know how
their money was being spent.4

RTI ACT
The basic object of the Right to Information Act is to empower the citizens, promote
transparency and accountability in the working of the Government, contain corruption, and make
our democracy work for the people in real sense. It goes without saying that an informed citizen
is better equipped to keep necessary vigil on the instruments of governance and make the
government more accountable to the governed. The Act is a big step towards making the citizens
informed about the activities of the Government.5

2
AIR 1988 Raj 2.
3
PUCL v UOI, AIR 2003 SC 2363.
4
State of U.P. v Raj Narain, AIR 1975 SC 865.
5
About Right to Information Act 2005, GOV. OF INDIA, rti.gov.in

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Brief History
The right to information was started being recognized as a right in 1766 in Sweden when RTI
laws were passed in the country. Since then, many democracies adopted RTI laws.

However, in India this story took a different turn in 1994 when Mazdoor Kisan Shakti Sangathan
(MKSS) [an organization for worker’s rights] started a grassroots campaign for Right to
Information – demanding information concerning development works in rural Rajasthan. The
movement grew and the campaign resulted in government of Rajasthan enacting a law on Right
to Information in 2000.

In 1996, National Campaign for People’s Right to Information (NCPRI), one among several civil
rights groups, was founded with the objective of getting legislation on RTI passed. In 1997,
Tamil Nadu became the first state in India to passed a law on Right to Information. In pursuance
with the commitment of National Democratic Alliance, the new coalition to implement its
National Agenda on Governance, introduced the Freedom of Information Bill, 2000 in the
Parliament. After having been pending for about 2 years the bill was finally passed by the
Parliament on 4th December, 2002 and it received the assent of President of India on 6th January,
2003. Meanwhile, instead of waiting for a central legislation, half a dozen states have enacted a
law on RTI Act. These include Goa (1977), Tamil Nadu (1977), Rajasthan (2000), Maharashtra
(2000), Karnataka (2000), and Delhi (2001). In 2004, the UPA government appointed a National
Advisory Council to monitor implantation of government schemes and advise government on
policy and law. NAC recommended changes to the existing Freedom of Information Act, 2002.
RTI Bill 2004 was tabled in Parliament as applicable only to the Union Government. The civil
society protested against the bill as most of the information required by the common man was
from state governments. After heavy lobbying by NCPRI and other organizations the RTI Act,
2005 was passed with 150 amendments.

Impact of RTI Laws

The enactment of RTI not only inspired a spate of other rights-based laws, but also embedded
transparency and accountability to the people within them. And despite all the problems with
implementation, the era of transparency is here to stay.

In India, studies and media reports show that RTI is being used by citizens, civil society and the
media as a remedy to individual injustices, to obtain access to government programmes,

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investigate government policy and decision-making, and expose corruption and misuse of public
resources.

While the empirical evidence regarding the impact of RTI laws on corruption and service
delivery is limited, there are several case studies that demonstrate how RTI laws, and access to
information more broadly, have helped citizens access services without having to resort to
bribes, identify corruption and leaks, and avoid the mismanagement of public funds.6

EXEMPTIONS UNDER RTI ACT 2005

No right is unfettered and therefore while promoting institutional integrity and transparency,
Sections 8, 9,10,11 and 24 of the RTI Act enlist exemptions/limitations on disclosure of certain
information. Essentially, as per the RTI Act such information is exempt from disclosure which
affect the sovereignty and integrity of the country in a prejudicial manner and also its security,
strategic, scientific or economic interests, commercial confidence, trade secrets, or intellectual
property, information causing breach of privilege of Parliament or the State Legislature,
6
Right to Information Laws: Impact and Implementation, TRANSPARENCY INTERNATIONAL,
https://www.u4.no/publications/right-to-information-laws-impact-and-implementation.pdf

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information forbidden to be published by any court of law etc. It also includes provisions for
protecting the privacy of an individual. Furthermore, certain intelligence and security
organizations have been exempted from disclosure of information, except information pertaining
to allegations of corruption and human rights violations. Moreover, wherever the competent
authority feels that larger public interest warrants disclosure, the information may be provided.

The PIO of a public authority can deny the following categories of information under Section
8(1)7 of the Act:

 Information whose disclosure will affect the security and integrity of India.
 Information barred from disclosure by a court.
 Information, whose disclosure would be a breach of privileges of the
Parliament/Assembly.
 Information relating to commercial secrets.
 Information, which is available to a person due to a special relationship of trust (fiduciary
relationship).
 Confidential information obtained from foreign governments.
 Information, the disclosure of which would endanger the life and physical safety of a
person.
 Information, which would affect the process of investigation.
 Records of meetings of cabinet (council of ministers).
 Personal information, the disclosure of which has no relationship to any public interest.

However, a PIO may allow access to information to the applicants in spite of the above
exemptions provided in Section 8(1), if public interest in providing the information is greater
than the harm done in private interest. Thus, the PIOs, while dealing with requests for
information must always remember that public interest shall outweigh private interest in the
disclosure of information, and that disclosure of information is the rule and denial of information
is an exception.

7
The Right to Information Act, 2005, No. 22, Acts of Parliament, 2005.

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Section 98 of the act provides that, Central Public Information Officer or a State Public
Information Officer, may reject a request for information where such a request for providing
access would involve an infringement of copyright subsisting in a person other than the State.

Section 249 states - Nothing contained in this Act shall apply to the intelligence and security
organisations specified in the Second Schedule, being organisations established by the Central
Government or any information furnished by such organisations to that Government:

Provided that the information pertaining to the allegations of corruption and human rights
violations shall not be excluded under this sub-section:

Provided further that in the case of information sought for is in respect of allegations of violation
of human rights, the information shall only be provided after the approval of the Central
Information Commission, and notwithstanding anything contained in section 7, such information
shall be provided within forty-five days from the date of the receipt of request.

In all the aforementioned provisions, exemptions u/s 8 of the Act are invoked, rather frequently,
to reject RTI applications in comparison to other provisions.

In the year 2017-18, 54.04% of total RTI applications were rejected under exemptions provided
u/s 8. However, in year 2018-2019, 50.10% applications were rejected u/s 8.10

Most commonly invoked clauses are Section8(1) (d), Section 8(1) (e) and Section 8(1) (j) of the
Act.

Since, Section 8 of the Act has been invoked various times in the past years, therefore, this paper
will deal with the exemptions provided under this provision. Thus, exemptions u/s 8(1) are very
important as it can act as a major constriction of right to information, if not invoked with due
diligence.

Exemptions u/s 8(1) are very important as they ensure balance between right to information and
right to privacy and protects officials from potential abuse in name of RTI. However, the

8
Id. at Section 9.
9
Id. at Section 24.
10
Annual Report, 2018-19, CIC, 17.

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discretionary powers provided u/s8 to the Information Officers may result in, abuse of power by
the officers.

RTI CONSTRICTED

In a public welfare law such as the RTI Act, objective of which is to maintain transparency and
openness in governance, the list of information that cannot be disclosed to the public (generally
known as ‘exemptions’) must be minimal, specific and narrowly defined. The courts have also
read these restrictions strictly and the same logic has to apply to the right to information as it is
an accepted part of the freedom of speech and expression.

The Act provides for limited exemptions, but it relies on better judgement of the Information
Officer, as to whether the information can be provided to the applicant or not. Sometimes the

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officials go beyond the exemptions and deny application. In this regard it would be worthwhile
to discuss some cases.

In the case of Reserve Bank of India and Ors. v. Jayantilal N. Mistry and Ors.11 “the Court had
to weigh between the public interest and fiduciary relationship (which is being shared between
the RBI and the Banks). Since, RTI Act is enacted to empower the common people, the test to
determine limits of Section 8 of RTI Act is whether giving information to the general public
would be detrimental to the economic interests of the country? To what extent the public should
be allowed to get information? In the context of above questions, it had long since come to our
attention that the Public Information Officers (PIO) under the guise of one of the exceptions
given Under Section 8 of RTI Act, have evaded the general public from getting their hands on
the rightful information that they are entitled to And in this case the RBI and the Banks have
sidestepped the General public's demand to give the requisite information on the pretext of
"Fiduciary relationship" and "Economic Interest". This attitude of the RBI will only attract more
suspicion and disbelief in them. RBI as a regulatory authority should work to make the Banks
accountable to their actions. Furthermore, the RTI Act Under Section 2(f) clearly provides that
the inspection reports, documents etc. fall under the purview of "Information" which is obtained
by the public authority (RBI) from a private body. From reading of Section 2(f), it can be
inferred that the Legislature's intent was to make available to the general public such
information which had been obtained by the public authorities from the private body. Had it
been the case where only information related to public authorities was to be provided, the
Legislature would not have included the word "private body". As in this case, the RBI is liable to
provide information regarding inspection report and other documents to the general public.”

Delhi High Court in the case of, Adesh Kumar v. Union of India & ors.12 respect to the case of
B.S. Mathur v. Public Information Officer13 where the authority denied information to the
respondent under section 8(1) (h) and the question before the court was Whether the disclosure
of the information sought by the Petitioner to the extent not supplied to him yet would “impede
the investigation” in terms of Section 8 (1) (h) RTI Act? The court held A public authority which
seeks to withhold information available with it has to show that the information sought is of the

11
(2016) 3 SCC 525
12
W.P. (C) 3543/2014
13
Id. at para 9.

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nature specified in Section 8 RTI Act. As regards Section 8 (1) (h) RTI Act, which is the only
provision invoked by the Respondent to deny the Petitioner the information sought by him, it will
have to be shown by the public authority that the information sought “would impede the process
of investigation.” The mere reproducing of the wording of the statute would not be sufficient
when recourse is had to Section 8 (1) (h) RTI Act. The burden is on the public authority to show
in what manner the disclosure of such information would ‘impede’ the investigation.

In the aforementioned judgements courts pointed out how exemptions must be construed and we
see, how public authority can mislead querist.

However, Supreme Court has been of the view that exemptions u/s 8 of the Act must be
interpreted in wide terms. Some High Courts have held that Section 8 of RTI Act is in the nature
of an exception to Section 3 which empowers the citizens with the right to information, which is
a derivative from the freedom of speech; and that therefore Section 8 should be construed
strictly, literally and narrowly. The Supreme Court in Central Board of Secondary Education
and Anr. vs. Aditya Bandopadhyay and Ors14., has disagreed with the said approach. The
Supreme Court has held that the RTI Act seeks to bring about a balance between two conflicting
interests (right to information and right to privacy), as harmony between them is essential for
preserving democracy and therefore, the Courts and Information Commissions enforcing the
provisions of RTI Act have to adopt a purposive construction, involving a reasonable and
balanced approach which harmonizes the two objects of the Act, while interpreting Section 8
and the other provisions of the Act. The Supreme Court has further held that indiscriminate and
impractical demands or directions under RTI Act for disclosure of all and sundry information
unrelated to transparency and accountability in the functioning of public authorities and
eradication of corruption, would be counterproductive as it will adversely affect the efficiency of
the administration and result in the executive getting bogged down with the non-productive work
of collecting and furnishing information.

In my opinion the aforementioned judgement of the court gives power to public authorities to use
their discretion widely. In recent years, it is seen that authorities have used exemptions provided
under section 8 as guise to evade from their duties.

14
(2011) 8 SCC 497

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However, there are some decisions of information commissions and courts which are
constricting this fundamental right of citizens which is neither sanctioned by the constitution or
the law. Highlighting one such instance - the Girish Ramchandra Deshpande15 judgment.

Former CIC Shailesh Gandhi has criticized the judgement in the given case and said, “an apex
court judgement is being taken as a precedent to deny information conveniently categorized as
personal. This conceals corruption and protects people who have submitted false bills or
certificates. It also ensures that fictitious beneficiaries of various schemes cannot be caught.”16

The facts of the case are- Girish Ramchandra Deshpande had sought copies of memos, show-
cause notices and censure/punishment awarded to a public servant. He had also demanded
details of assets and gifts received by this public servant. Since the Central Information
Commission (CIS) gave an adverse ruling, he finally went to the Supreme Court.

The Supreme court’s judgement states that-

13 We are in agreement with the CIC and the courts below that the details called for by the
petitioner i.e. copies of all memos issued to the third respondent, show cause notices and orders
of censure/punishment etc. are qualified to be personal information as defined in clause (j) of
Section 8(1) of the RTI Act. The performance of an employee/officer in an organization is
primarily a matter between the employee and the employer and normally those aspects are
governed by the service rules which fall under the expression “personal information,” the
disclosure of which has no relationship to any public activity or public interest. On the other
hand, the disclosure of which would cause unwarranted invasion of privacy of that individual.
Of course, in a given case, if the Central Public Information Officer or the State Public
Information Officer of the Appellate Authority is satisfied that the larger public interest justifies
the disclosure of such information, appropriate orders could be passed but the petitioner cannot
claim those details as a matter of right.

14 The details disclosed by a person in his income tax returns are “personal information” which
stand exempted from disclosure under clause (j) of Section 8(1) of the RTI Act, unless involves a
larger public interest and the Central Public Information Officer or the State Public Information

15
Girish Ramchandran Deshpandey v. Chief Information Commissioner, 2013, 1, SCC, 212.
16
Shailesh Gandhi, Right to Information Constricted, EPW JOURNAL, Vol. 52, Issue No. 50, 16 Dec, 2017

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Officer or the Appellate Authority is satisfied that the larger public interest justifies the
disclosure of such information.

Former CIC states following reasons as to why impugned judgment should not be treated as a
precedent:

(i) It is devoid of any detailed reasoning and does not lay down a rationale. Being a decision given to
reject a special leave petition (SLP), it did not need to give detailed reasoning.

(ii) It does not analyze whether a public servant’s work and assets is information, which is a public
activity, or not. The judgment, when stating that certain matters are between the employee and the
employer, misses the fact that the employer is the “people of India.”

(iii) It has completely forgotten the proviso to Section 8(1)(j), which requires subjecting a proposed
denial to this acid test.

(iv) It has not considered the clear rationale of the Rajagopal judgment or the Association for
Democratic Reforms judgment.

The Girish Ramchandra Deshpande judgment cannot lay down the law. The findings have been used
to reject demands for information wrongly in two other Supreme Court judgments. Governments
have issued circulars to effectively bar any personal information from being given and information
commissions are also blindly following this. These denials are without a legal base, contradict earlier
Supreme Court judgments, and constrict the RTI law and its ability to curb corruption and
wrongdoing. This is leading to the denial of the following types of information under the RTI Act’s
Section 8(1)(j):

(i) Allocation of subsidized plots to politicians, officers and judges

(ii) Beneficiaries of various subsidy and other welfare schemes: There are many ghost beneficiaries.
Some who are really wealthy also avail of these.

(iii) Educational, caste, income certificates of people: There are instances where RTI has uncovered
fake education certificates, even of doctors working in government hospitals.

(iv) Marks obtained in competitive exams: In many cases, people with higher marks have not been
chosen.

(v) Foreign visits.

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(vi) Details regarding a public servant: memos, show-cause notices, censure/punishment awarded,
details of movable and immovable properties, details of investments, lending and borrowing from
banks and other financial institutions, and gifts received.

(vii) Income tax returns: It is a fact that the affidavits of politicians who stand for elections are never
verified with their income tax returns. These are not given under the RTI Act also.

The nation must safeguard this important right and not allow it to be amended by gross
misinterpretation. We must not allow adjudicators to take away our fundamental right, one that has
been well-defined by our Parliament.17

In a recent judgement Madras High Court mentioned the issue of PIOs evading their duties under the
garb of exemptions. The court observed-

The next plea raised by the learned Senior Counsel for TNPSC that the queries in respect of (d
to f) have been rejected only in terms of Section 8(1)(d) of RTI Act, is wholly unjustified on the
ground that the purpose of enactment of RTI Act itself is to ensure transparency in all respects.
Moreover, a reading of the said section shows that it relates to commercial confidence, trade
secrets, etc., and it does not strictly prohibit the authority concerned from providing such
details, as divulging of caste details will surely be beneficial to candidates to doubly ascertain
either about their induction or rejection and as such, the quoting of the aforesaid provision is
highly irrelevant to the present context, from which, it is apparent that TNPSC had first decided
not to give details and thereafter, searched for relevant provisions. For better understanding,
Section 8(1)(d) of the RTI Act is extracted hereunder:

“(d) information including commercial confidence, trade secrets or intellectual property, the
disclosure of which would harm the competitive position of a third party, unless the competent
authority is satisfied that larger public interest warrants the disclosure of such information.”18

Bench added that nowadays, the Officials are used to adopt a tactic answer in a mechanical
manner that the information sought for is exempted in the light of Section 8(1)(d) of the Act,
without actually ascertaining as to whether the information sought falls within the ambit of the
said provision.

17
Id at Page 7.
18
Tamil Nadu Public Service Commission v. P. Muthian, 2020, SCC OnLine Mad, 2167.

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Officers using the above-said tactic should be taught a lesson as they are unfit to hold the post of
Public Information Officer or any other post in connection with the discharge of duties under
the RTI Act and they should be shown the doors.

Court directed TNPSC to furnish the details to the respondent within a period of 1 month.
TNPSC shall also ascertain the names of the Officials who have failed to discharge their official
duties as adumbrated under the RTI Act, 2005.

Yet, in another decision CIC states:

Commission is baffled at the sheer complacency of Lt. Col. JS Brar, PIO in concluding in his
written submissions that the information has been rightly denied by the then PIO without even
justifying how disclosure of posting/transfer roster will invade the privacy of third parties. He
has merely relied on a decision of this bench to substantiate the denial but has not explained
how the said case is relevant to the facts of the instant case. In the earlier matter cited by the
PIO, the RTI Applicant had sought for information pertaining to service matters of her husband
while in this case Appellant has sought for posting roster of civilian employees. Even further,
PIO has urged that there is no larger public interest in the disclosure of this information. PIO
shall note that the aspect of larger public interest is decided only when it is established that
information sought is exempt under Section 8(1)(j) of RTI Act.19
All the aforementioned decisions of courts and commission points to the fact that Information
Officers have been negligent in disposal of their duty. The right conferred upon the citizens by,
the Constitution and the RTI Act, is being diluted by such practices. There is a fine line between
right to information and right to privacy, the former concerns right of public at large; which is
extremely essential to keep public discourse in flow, while the latter concern an individual, and
the PIOs need to be extremely cautious while dealing with RTI requests, so as to strike a balance
between the two rights.

19
R V Wagh v. CPIO, Records the Mech Infantry Regiment in File No: CIC/IARMY/A/2018/101803/SD, Date of
Decision: 06.02

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Conclusion

Keeping in mind the decisions of the courts and commission, it seems fair to conclude that laxity
of information officers and lack of incentivizing programmes are leading us to a situation where
the right is being diluted. For instance, taking into consideration Girish Deshpande decision
According to RTI activists, this broader definition of personal data would result in a lot of
information about public officials being exempted from the RTI act. Now, if somebody is
corrupt, asking for information on that person will harm his or her reputation, and it should. If
the definition of Section 8(1)(j) is changed, we won't be able to access information which would
be important to hold public officials accountable.

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The reasons for such attitude are-a) Lack of motivation among CPIOs: In addition to lack of
resources, CPIOs lack the motivation to implement RTI Act. During the RTI workshops
organized in the surveyed states, CPIOs cited that there were no incentives for taking on the
responsibility of a CPIO. However, penalties were imposed in cases of non-compliance. It was
also observed that there is a wide variance in the seniority levels of CPIOs, b) Lack of
Monitoring and Review mechanism. However, where the central information commission at the
time of deciding any complaint or appeal is of the opinion that the public information officer has
without any reasonable cause and persistently, failed to receive an application for information or
has not furnished the information within time specified malafidely denied the request for
information knowingly given incomplete information or misleading the information or destroyed
information which was the subject to request or obstructed in any manner in furnishing the
information it may recommend for disciplinary action against the public officer. CPIOs do not
have the inspiration to actualize RTI Act. Amid the RTI workshops composed in the reviewed
states, CPIOs referred to that there were no motivations for assuming on the liability of a CPIO;
anyway, punishments were forced in instances of rebelliousness. It was additionally watched that
there is a wide difference in the rank levels of CPIOs.

On the other hand, the annual CIC’s annual report shows a downfall in the number of
applications registered since past two-three years. So, it’s a good sign. This Act can be
implemented in a better way for good governance which promotes openness, transparency, and
accountability in the public administration.

Bibliography

Annual Report CIC. Government Report. New Delhi: CIC, 2018-2019. PDF.

Gandhi, Shailesh. "Right to Information Constricted." EPW (2017).

MS, Neelina. How Broad Interpretaion of Personal Information is Disarming RTI, The Carvan.
2019.

Sayyed, Praveen. "Exemptions from Disclosure of Information Under RTI Act 2005: A
Methodical Review." 2016. www.manupatra.com. Oct 2020.

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