Delhi High Court
Administrative and Public LawConstitutional Law

RTI Disclosure Cannot Be Ordered Without Specific Identification of Withheld Information.

Anurag Kumar vs The Central Public Information Officer Bank Of Baroda And Anr.

Delhi High CourtJUDGMENT: October 05, 20262 MIN READSOURCE JUDGMENT
RTI Disclosure Cannot Be Ordered Without Specific Identification of Withheld Information.. Anurag Kumar vs The Central Public Information Officer Bank Of Baroda And Anr.. Delhi High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a former Bank of Baroda employee whose termination orders had been set aside by the Allahabad High Court, filed two RTI applications seeking, among other things, service records, personal files, circulars concerning jurisdictional changes, and approval notes relating to the Bank’s appeal.

Source reference: para. 2–4

The CPIO responded that the requests were voluminous, repetitive, and ambiguous, and supplied a note sheet recording approval to file the appeal; the First Appellate Authority and the Central Information Commission dismissed the petitioner’s challenges.

Source reference: para. 5–8

The petitioner had previously been permitted to inspect his personal file and, according to the Bank, inspected 17 files at its Regional Office.

Source reference: para. 9

He then challenged the Commission’s decision under Article 226 of the Constitution.

Source reference: para. 1, 8
02

Issues

Whether the Commission’s dismissal of the petitioner’s second appeals warranted interference under Article 226 of the Constitution.

Source reference: para. 10, 14

Whether the petitioner identified specific information held by the Bank, liable to disclosure under the Right to Information Act, 2005, that had been withheld.

Source reference: para. 11–13
03

Law Applied

The Court considered the Right to Information Act, 2005, under which a direction to disclose information requires identification of information that is held by the public authority and is liable to disclosure.

Source reference: para. 13

It also applied its jurisdiction under Article 226 of the Constitution to review the Commission’s order, finding no basis for interference where the petitioner had not demonstrated that any specific, disclosable document had been withheld.

Source reference: para. 13–14
04

Reasoning

The Court found that the petitioner had been allowed to inspect his service records and that he had received the note sheet approving the Bank’s appeal.

Source reference: para. 9, 12

Although he made general assertions about missing service records, personal files, jurisdictional-change circulars, and approval notes, he did not identify any particular document that remained undisclosed despite being held by the Bank and liable to disclosure.

Source reference: para. 11–13

The Court therefore found no ground to interfere with the Commission’s order under Article 226.

Source reference: para. 14
05

Holding

The Court held that the petitioner had not established that specific, disclosable information was withheld and found no ground for interference with the Commission’s order.

The writ petition was dismissed.

Source reference: para. 13–15
Delhi High Court

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Anurag KumarvsThe Central Public Information Officer Bank Of Baroda And Anr.

Delhi High Court · October 05, 2026

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