New Delhi: The Delhi High Court has ruled that educational qualifications, including degrees and marks, are protected as “personal information” under Section 8(1)(j) of the Right to Information (RTI) Act and cannot be disclosed simply to satisfy public curiosity.
The ruling came in response to a challenge against a 2016 order by the Central Information Commission (CIC), which had directed Delhi University to share records related to Prime Minister Narendra Modi’s undergraduate degree. Justice Sachin Datta, delivering the verdict, clarified that public interest must not be confused with public curiosity.
“Just because something interests the public does not mean it serves the public interest,” the court observed, emphasizing that the RTI Act aims to maintain a balance between transparency and individual privacy. The judgment underscored that academic records are held in confidence and disclosure without sufficient justification would breach the trust between universities and their students.
The court likened this relationship to other fiduciary ones—such as doctor-patient or lawyer-client—highlighting the university’s duty to protect students’ private data.
Rejecting the CIC’s stance that university degree registers are public records, the court ruled that such records cannot be accessed by third parties unless a compelling public interest is demonstrated. Consequently, the CIC’s order allowing inspection of Delhi University records from 1978—the year PM Modi is said to have completed his Bachelor’s degree—was overturned.
SolicitorGeneral Tushar Mehta, representing Delhi University, argued that permitting disclosure of such records would open the floodgates to politically motivated or publicity-driven RTI applications. He added that academic records could be produced in court if required but should not be released into the public domain.
The legal battle began with RTI applications in 2016, which led to the CIC’s now-quashed order. The High Court had initially stayed the directive in 2017 and has now concluded that educational documents, including degrees and marksheets, are protected under the RTI’s privacy safeguards.
The judgment reinforces the principle that the RTI Act does not authorize the disclosure of personal data unless a larger public interest is clearly established.
