This court order from the High Court of Delhi pertains to several connected petitions, including W.P.(C) 600/2017, W.P.(C) 1051/2017, and others. The judgment was pronounced on August 25, 2025.
The primary issue in W.P.(C) 600/2017 is a challenge by the University of Delhi to an order from the Central Information Commission (CIC). The CIC’s order stems from an RTI application filed by a man named Neeraj, who requested the results of all students who appeared for the Bachelor of Arts exam in 1978, including their roll numbers, names, father’s names, and marks.
Initially, the University of Delhi’s Central Public Information Officer (CPIO) rejected the request, stating the information was personal data of individual students and was exempt under Section 8(1)(j) of the RTI Act. This decision was upheld by the First Appellate Authority.
However, the CIC, in its order, sided with the RTI applicant. The CIC argued that a university’s graduation records are a form of public record, similar to land or property documents, and therefore not considered personal information. The CIC also referenced a Supreme Court case, Mairembam Prithviraj v. Pukhrem Sharat Chandra Singh, which emphasized the fundamental right of a voter to know a candidate’s educational qualifications. Based on this, the CIC directed the University of Delhi to provide the certified copies of the relevant register’s extracts to the RTI applicant.
An application was filed by RTI activists to intervene in the case to assist the court. The court, however, dismissed this intervention application, stating that the petitioners were not necessary or proper parties and lacked legal standing to intervene. The court also noted that the petitions were not of a public interest nature, and the intervention would unduly expand the scope of the proceedings.
The court order details the factual background of several connected petitions, all challenging CIC orders related to the disclosure of student information under the RTI Act. It is noted that a Delhi High Court order dated January 23, 2017, in W.P.(C) No. 600/2017, had stayed the CIC’s order. The court also criticized the CIC’s approach, stating it was based on a “subjective critique rather than on the interpretation and application of the statutory provisions as they exist”.
Key Highlights
The Delhi High Court, presided over by Justice Sachin Datta, quashed an earlier Central Information Commission (CIC) order that had required Delhi University (DU) to disclose information about Prime Minister Narendra Modi’s bachelor’s degree.
The CIC order, issued in December 2016, had allowed inspection of DU’s records of students who passed the B.A programme in 1978—the year PM Modi also graduated.
DU had contested this demand, arguing that student records are maintained in a fiduciary capacity, and that mere curiosity does not justify disclosure under the RTI Act. DU offered to show the records to the court but opposed public disclosure.
The Court agreed, holding that educational qualifications, including degrees, marks, and grades, amount to “personal information” under Section 8(1)(j) of the RTI Act. Disclosing them without compelling public interest would infringe on the right to privacy.
- CIC Allowed public inspection of DU’s 1978 BA student records (PM Modi included)
- DU contested and posed that student records are private and can’t be disclosed just out of curiosity; willing to show court, not public at large.
- Delhi HC (2025) Declared such academic records as personal information; quashed CIC’s directive
- Legal Basis Section 8(1)(j) of RTI Act — “personal information” protected unless overriding public interest