PIO must collate information from different branches and cannot mechanically deny RTI requests under Section 8(1)(j).

The petitioner filed an RTI application on 16.08.2020 seeking 17 points of information from AIIMS regarding wage rates (1994–2003), rules for festival bonuses, and copies of specific office memoranda/departmental orders

The Public Information Officer (PIO) denied several queries citing "personal information" under Section 8(1) without detailed reasoning and directed the petitioner to different departments for other queries, stating some info was in the "public domain"

Both the First Appellate Authority and the Central Information Commission (CIC) dismissed the appeals, with the CIC claiming the matter was barred by res judicata and that eligible information had already been furnished

The petitioner challenged these orders via a writ petition before the Delhi High Court.

1. Whether a PIO can validly reject an RTI request by merely citing Section 8(1) without assigning specific reasons or examining the severability of information

2. Whether a PIO is obligated to consolidate information from different branches of the same public authority rather than directing the applicant to various departments

3. Whether the principle of res judicata can be invoked to dismiss a second appeal without a clear analysis of the identity of the subject matter

Section 5(3) of the RTI Act, 2005, which mandates PIOs to render reasonable assistance

Section 5(4) and 5(5), which empower PIOs to seek assistance from other officers within the same authority

Section 6(3) regarding the mandatory transfer of applications to other public authorities within five days

Section 8(1)(j) regarding the exemption of personal information

Section 10, which mandates the "doctrine of severability" for non-exempt portions of a record

The Court observed that the PIO’s approach of "driving the applicant from pillar to post" was contrary to the mandate of the Act

Under Section 5(4), the PIO had the statutory power to collect information from various wings of the same authority rather than forcing the petitioner to approach different branches

Regarding the denial of information, the Court held that a "bare reference" to Section 8(1) without explaining how the disclosure would cause an unwarranted invasion of privacy is insufficient

The Court further noted that the respondents failed to apply the doctrine of severability under Section 10 for records containing both exempt and non-exempt data

the Court found the CIC's invocation of res judicata flawed as it lacked a comparative analysis of the previous and current subject matter

It held that the PIO must personally collate information from all respective branches and provide it to the petitioner

If any information is withheld, specific reasons must be communicated

The Court directed that all information be furnished free of cost

The writ petition was disposed of accordingly