Public Authority qualifies as an aggrieved ‘person’ entitled to file statutory appeals under the RTI Act.

The Petitioner (Supreme Court of India) filed a writ petition under Article 226 of the Constitution to challenge an order dated 07.11.2025 passed by its own Registrar-cum-First Appellate Authority (FAA)

The FAA order directed the disclosure of examination-related information, including evaluated answer scripts and moderation data, to the Respondent under the RTI Act

The Petitioner approached the High Court directly, bypassing the statutory Second Appeal to the Central Information Commission (CIC), arguing that a "public authority" does not qualify as a "person" entitled to file an appeal under Section 19 of the RTI Act

1. Whether the term "any person" in Section 19(1) of the RTI Act excludes a "public authority," thereby barring them from preferring statutory appeals under Sections 19(1) and 19(3)

2. Whether the writ petition is maintainable despite the availability of an alternative statutory remedy under Section 19(3) of the RTI Act

The Court primarily interpreted Section 19 of the RTI Act, which grants the right of appeal to "any person" aggrieved by a decision of a Public Information Officer (PIO)

Section 3(42) of the General Clauses Act, 1897, which defines "person" to include any company, association, or body of individuals, whether incorporated or not

The principle of statutory interpretation that "person" includes juristic entities unless a contrary intention appears

the doctrine that a PIO functions as an independent quasi-judicial authority, separate from the public authority that employs them

GH Sharanappa v. Commissioner, Karnataka State Information Commission regarding the breadth of the right to appeal for aggrieved persons

The Court rejected the Petitioner’s contention that a public authority cannot be a "person" under Section 19, labeling the argument as lacking merit

It reasoned that while the PIO is part of the public authority, the law requires them to act independently; thus, the PIO and the public authority can wear "two different hats"

The Court noted that Section 19(1) creates a broad category for "any person" aggrieved, and the maintainability of an appeal depends on whether the entity is "aggrieved," not whether it is a natural person

Referring to legal commentaries and the General Clauses Act, the Court determined that "public authority" is a juristic entity and thus fits within the wide definition of "person"

the Court observed that accepting the Petitioner's view would bypass the specialized hierarchical mechanism of the RTI Act and unnecessarily burden the Writ Court, which is "unfathomable" in a designed statutory scheme

Consequently, the Petitioner has an efficacious alternative remedy under Section 19(3) of the Act

The writ petition was dismissed, granting the Petitioner liberty to approach the CIC

The Court ordered that the time spent in the present proceedings be excluded for the purposes of limitation when filing the Second Appeal