Public authority qualifies as an aggrieved “person” entitled to prefer Second Appeals under the RTI Act.

The Petitioner (Supreme Court of India) challenged an order dated 11.11.2025 passed by its own Registrar-cum-First Appellate Authority (FAA) under the Right to Information Act, 2005 ("RTI Act")

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

The Petitioner approached the High Court directly via a writ petition instead of filing a Second Appeal before the Central Information Commission (CIC) under Section 19(3) of the RTI Act

The Petitioner argued that as a "public authority" defined under Section 2(h), it is excluded from the term "any person" used in Section 19, and therefore lacks the standing to prefer a statutory appeal

Whether the term "person" in Section 19 of the RTI Act excludes a "public authority," thereby precluding them from filing a statutory appeal

Whether the writ petition is maintainable in light of the alternative statutory remedy available under Section 19(3) of the RTI Act

The court primarily applied Section 19(1) and 19(3) of the RTI Act, which govern the appellate mechanism for "any person" aggrieved by a decision of an Information Officer

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

Principle that a Public Information Officer (PIO) acts as an independent quasi-judicial authority separate from the public authority itself

GH Sharanappa v. Commissioner, Karnataka State Information Commission, which held that the right of appeal is a creature of statute available to any "aggrieved person"

The Court dismissed the Petitioner’s contention as meritless, holding that the RTI Act intended the Information Officer to function as an independent authority separate from the "whims" of the public authority

Because the officer wears a "different hat" in law, a public authority can be "aggrieved" by the officer's decision

The Court determined that the word "person" must be given its ordinary, wide legal meaning, which encompasses juristic entities and bodies of individuals

Section 19(1) creates two categories of appellants: the information seeker and "any other person" aggrieved by a decision; the latter is broad enough to include the public authority

The Court observed that accepting the Petitioner’s argument would create an "unfathomable" situation where every public authority would have to bypass the hierarchical appellate mechanism and approach the Writ Court for every grievance

The writ petition was dismissed due to the availability of an efficacious alternative remedy

The Court granted the Petitioner liberty to file an appeal before the CIC and directed that the time spent in the current writ proceedings be excluded when calculating the limitation period for said appeal