Disclosure of witness statements given in confidence for law enforcement is exempt under Section 8(1)(g) of the RTI Act.

The petitioner, Pavit Singh, sought the disclosure of recorded statements or names of seven property owners/occupants from the Central Bureau of Investigation (CBI). These statements formed the basis of a "Self-Contained Note" sent by the CBI to the Delhi Police on 16.10.2019, alleging that the petitioner and his father were involved in blackmail.

The Public Information Officer (PIO), First Appellate Authority, and the Central Information Commission (CIC) via order dated 28.07.2025, denied the request on the grounds that the information was provided in "State confidence".

The petitioner challenged the CIC's order through this writ petition under Article 226 of the Constitution.

1. Whether the disclosure of statements given by witnesses in confidence during a preliminary inquiry is exempt under Section 8(1)(g) of the RTI Act.

2. Whether the RTI Act can be utilized as a mechanism to challenge the veracity of investigative material used in potential criminal or civil proceedings.

Section 8(1)(g) of the Right to Information Act, 2005, which exempts information the disclosure of which would endanger the life or physical safety of any person or identify a source of information given in confidence for law enforcement.

The precedent Bihar Public Service Commission v. Sayyed Hussain Abbas Rizvi (2012) 13 SCC 182, which established that "life" in Section 8(1)(g) must be construed liberally and that the concerned authority is entitled to form an opinion on the likelihood of danger to physical safety.

The court reasoned that the statements in question were provided to the CBI by seven individuals in confidence during a court-directed preliminary inquiry.

Applying the liberal interpretation from Sayyed Hussain Abbas Rizvi, the court found that the CPIO was entitled to invoke the exemption because disclosing the identity of sources who provided information for law enforcement purposes falls squarely within the protection of Section 8(1)(g).

the court clarified that the RTI Act is intended to promote transparency in public authorities and is not a substitute for legal remedies in criminal or civil law. Consequently, a petitioner cannot use a writ of certiorari under the RTI Act to collaterally attack the veracity of investigative evidence or witness statements.

The petition was dismissed, and no grounds for interference under Article 226 were found. However, the court granted liberty to the petitioner to challenge the veracity or existence of said statements through appropriate legal channels outside of the RTI framework.