Delhi High Court
Administrative and Public LawConstitutional Law

Public expenditure alone does not justify disclosure of personal LTC and medical records under RTI.

Sachin Kumar Daksh vs Director-Admin And Finance & Anr.

Delhi High CourtJUDGMENT: October 07, 20262 MIN READSOURCE JUDGMENT
Public expenditure alone does not justify disclosure of personal LTC and medical records under RTI.. Sachin Kumar Daksh vs Director-Admin And Finance & Anr.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner sought, under an RTI application dated 24 June 2024, an employee’s LTC records, travel and settlement details, CGHS benefits and medical bills concerning his dependants, and family declaration forms.

Source reference: pp. 1–5, paras. 2–6

The DGCA CPIO refused disclosure on the ground that the information was exempt; the First Appellate Authority and the Central Information Commission upheld that refusal under Section 8(1)(j) of the RTI Act.

Source reference: pp. 1–5, paras. 2–6

The petitioner’s writ petition contended that public expenditure and the pursuit of vigilance complaints justified disclosure.

Source reference: pp. 1–5, paras. 2–6

The respondents also pointed to matrimonial disputes between the petitioner and the employee’s family

Source reference: pp. 1–5, paras. 11–12
02

Issues

1. Whether the requested LTC, medical-benefit and family-declaration records constituted third-party personal information exempt from disclosure under Section 8(1)(j) of the RTI Act

Source reference: pp. 3–4, paras. 7–9

2. Whether the involvement of public funds or the petitioner’s stated intention to pursue vigilance complaints established a larger public interest warranting disclosure

Source reference: pp. 2–5, paras. 6, 10–11
03

Law Applied

Section 8(1)(j) of the Right to Information Act, 2005, as applied in the judgment, exempts personal information where disclosure has no relationship to public activity or interest, or would cause an unwarranted invasion of privacy, unless the competent authority is satisfied that larger public interest justifies disclosure

Source reference: p. 3, para. 7

The judgment cites no judicial precedents.

Source reference: no citation
04

Reasoning

The Court found that the application sought more than aggregate information about DGCA expenditure: it sought identifiable dependants’ travel, medical treatment and expenses, as well as the employee’s family declarations.

Source reference: pp. 3–5, paras. 8–13

These details concerned the private affairs of the employee and, particularly, family members who were third parties.

Source reference: pp. 3–5, paras. 8–13

Reimbursement from public funds did not, by itself, convert those personal particulars into disclosable information.

Source reference: pp. 3–5, paras. 8–13

The petitioner showed no overriding larger public interest; neither the assertion of public expenditure nor the intention to pursue vigilance complaints displaced the exemption.

Source reference: pp. 3–5, paras. 8–13

The Court also considered the matrimonial-dispute context and observed that RTI could not be used to settle personal scores

Source reference: pp. 3–5, paras. 8–13
05

Holding

The Court held that the requested records were exempt third-party personal information and that no larger public interest justified disclosure.

It dismissed the writ petition and disposed of any pending applications.

Source reference: p. 5, paras. 14–15
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Right to Information Act, 20051

Delhi High Court

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Sachin Kumar DakshvsDirector-Admin And Finance & Anr.

Delhi High Court · October 07, 2026

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