Delhi High Court

Third-party personal documents submitted for CGHS dependency benefits are exempt from disclosure under Section 8(1)(j) of the RTI Act.

Vikas Nagar vs Union Of India & Anr.

Delhi High CourtJUDGMENT: July 02, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellant’s late wife, Ambika, daughter of a retired Central Government official (Shri Shyam Singh Khinchee), was included as a dependent beneficiary under the Central Government Health Scheme (CGHS) by her father in 2020

Source reference: p. 2

The appellant alleged that this inclusion was obtained through false declarations stating that Ambika was wholly dependent on her father and separated from her husband

Source reference: p. 2

On October 4, 2022, the appellant filed an RTI application seeking copies of his father-in-law’s CGHS application, supporting affidavits, file notings, and medical claim details

Source reference: p. 2

The CPIO and subsequent appellate authorities, including the Central Information Commission (CIC), denied the request under Section 8(1)(j) of the RTI Act, 2005, citing "third-party information"

Source reference: p. 3

The appellant challenged these orders via a writ petition, which was dismissed by a Single Judge on February 19, 2026

Source reference: p. 1-3

The appellant thereafter filed this intra-Court letters patent appeal

Source reference: p. 1
02

Issues

1. Whether the information and documents regarding a third party's application for CGHS benefits constitute "personal information" exempted from disclosure under the RTI Act

Source reference: p. 3, para 7; p. 4, para 9

2. Whether the fact that the third party’s application contained references to the appellant’s marital status transforms the requested documents into the appellant’s own personal information

Source reference: p. 3, para 8; p. 4, para 9
03

Law Applied

Section 8(1)(j) of the Right to Information Act, 2005, which exempts the disclosure of personal information which has no relationship to any public activity or interest, or which would cause unwarranted invasion of the privacy of the individual unless a larger public interest justifies such disclosure

Source reference: p. 3, para 6

Interpretation highlighting the distinction between personal information concerning the applicant versus information concerning a third party

Source reference: p. 4, para 10
04

Reasoning

The Court rejected the appellant's contention that the information pertained to him simply because it mentioned his marital status

Source reference: p. 4, para 9

The Bench reasoned that the documents sought—specifically the application, affidavits, and medical claims filed by Shri Shyam Singh Khinchee—were "personal to" the father-in-law as they were submitted by him to avail of a government benefit

Source reference: p. 4, para 9-10

The Court held that merely because a third party makes averments regarding the appellant in a declaration, it does not strip those documents of their private character or entitle the appellant to circumvent the protections of Section 8(1)(j)

Source reference: p. 4, para 9

The Court noted that the appellant had already unsuccessfully challenged the validity of his wife’s CGHS inclusion in separate proceedings (W.P.(C) 16539/2025) and could not use the current RTI appeal to re-litigate those grievances

Source reference: p. 5, para 14-16
05

Holding

The Court dismissed the appeal, holding that the information sought was correctly classified as third-party personal information exempt from disclosure under Section 8(1)(j) of the RTI Act

The Court found no illegality in the Single Judge’s order or the findings of the CIC

Source reference: p. 4, para 11

While the Court declined to grant the relief sought, it noted that the appellant remains free to challenge the dismissal of his separate writ petition regarding the "false and fabricated" documents before the appropriate forum. No costs were ordered

Source reference: p. 4, para 13; p. 5, para 16
Delhi High Court

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Vikas NagarvsUnion Of India & Anr.

Delhi High Court · July 02, 2026

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