Delhi High Court

Statutory finality of RTI orders cannot bar writ jurisdiction under Article 226 of the Constitution.

Ambika Gupta vs Cpio Lic Of India

Delhi High CourtJUDGMENT: April 08, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant filed an application under the Right to Information Act, 2005 ("RTI Act") seeking a comprehensive list of all insurance policies where she was the insured party, without providing specific policy numbers

Source reference: para. 3

The CPIO of the Life Insurance Corporation of India ("LIC") rejected the request, stating that records could not be retrieved without policy numbers

Source reference: para. 5

Following an unsuccessful first appeal, the Central Information Commission ("CIC") directed LIC to establish a retrieval system for cases lacking policy numbers and to furnish the requested information

Source reference: para. 8-10

LIC challenged this before a Single Judge, who modified the CIC's order by refraining from mandatory directions regarding system overhaul but granted the Appellant liberty to file a fresh application using alternative identifiers (e.g., name, DOB, mobile number, bank details)

Source reference: para. 11-13

The Appellant filed this intra-court appeal, arguing that the Single Judge lacked jurisdiction to modify the CIC's "final and binding" order

Source reference: para. 15-16
02

Issues

1. Whether the Single Judge exceeded the jurisdiction of Article 226 of the Constitution by modifying an order of the CIC despite the finality attached by Section 19(7) of the RTI Act.

Source reference: para. 15-16, 37

2. Whether Section 23 of the RTI Act bars the High Court from entertaining writ proceedings against orders passed under the Act.

Source reference: para. 17, 39

3. Whether LIC can be mandated to retrieve policy information solely based on a name without policy numbers or other identifying particulars.

Source reference: para. 26, 34
03

Law Applied

Section 19(7) of the RTI Act, which states CIC decisions are binding, and Section 23, which bars courts from entertaining suits or proceedings in respect of orders made under the Act

Source reference: para. 16-17

Judicial review is a "basic feature" of the Constitution of India, meaning Article 226 jurisdiction remains plenary and cannot be ousted by statutory finality

Source reference: para. 38

The practical limitations of public authorities under the RTI Act when faced with requests for information that are administratively impossible to fulfill without specific parameters

Source reference: para. 34
04

Reasoning

The Court held that the Appellant’s challenge to the Single Judge's jurisdiction was "highly misconceived"

Source reference: para. 20, 38

The Court clarified that statutory clauses declaring an order "final and binding" (Section 19(7)) or barring court jurisdiction (Section 23) apply to civil suits and lower courts, but cannot curtail the High Court’s constitutional power of judicial review under Article 226

Source reference: para. 37-39

On the merits, the Court noted that LIC manages over 27 crore policies; searching such a vast database without specific identifiers is practically impossible

Source reference: para. 26, 34

The Court found the Single Judge's approach balanced: it protected the Appellant's right to information by allowing retrieval via alternative details (DOB, mobile number, bank account) while recognizing the security risk of disclosing sensitive policy data to third parties without rigorous identification

Source reference: para. 28, 32-33

The Court concluded that the Single Judge correctly characterized the CIC's broad systemic directions as advisory rather than mandatory

Source reference: para. 29, 35
05

Holding

The Division Bench dismissed the appeal and upheld the Single Judge’s order

The Court held that Article 226 jurisdiction is not barred by Sections 19(7) or 23 of the RTI Act

Source reference: para. 38-39

The Court held that while a policy number is not strictly necessary for an RTI request, the applicant must provide sufficient identifying details (Name, DOB, Address, Mobile, and Bank details) to enable the public authority to retrieve the data

Source reference: para. 33-34

No order as to costs was made

Source reference: para. 42
Delhi High Court

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Ambika GuptavsCpio Lic Of India

Delhi High Court · April 08, 2026

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