Central public information officer, SC of India v/s Subhas chandra Agrawal

Here’s a structured case law summary of Central Public Information Officer, Supreme Court of India v. Subhash Chandra Agarwal, which is a landmark case on Right to Information (RTI), 2005.

Case Law Summary

Case Name:  Central Public Information Officer, Supreme Court of India v. Subhash Chandra Agarwal

Citation: (2020) 5 SCC 481

Court: Supreme Court of India, Constitution Bench (5 Judges)

Bench:  Justice Ranjan Gogoi (CJI), Justice N.V. Ramana, Justice D.Y. Chandrachud, Justice Deepak Gupta, Justice Sanjiv Khanna

Date of Judgment: 13 November 2019

The case’s facts are as follows:

RTI activist Subhash Chandra Agarwal filed applications under the Right to Information Act, 2005 (RTI Act) to obtain information about:

1. Correspondence between the Chief Justice of India (CJI) and other constitutional authorities about High Court and Supreme Court judge appointments.
   
   2. Details regarding assets declared by Supreme Court and High Court justices.
   3. A correspondence about alleged attempts by a Union Minister to affect court rulings between the CJI and Justice R. Regupathi of the Madras High Court

•  The Central Public Information Officer (CPIO) of the Supreme Court denied the information, claiming exemption under Section 8(1)(j) of the RTI Act (personal information) and arguing that the Office of the Chief Justice of India (CJI) was not a ‘public authority’ under the RTI Act.
• The matter reached the Supreme Court after conflicting opinions at the Central Information Commission (CIC) and the Delhi High Court.

Issues Before the Court:

1. Whether the office of the Chief Justice of India comes under the definition of “public authority” under Section 2(h) of the RTI Act.
2. Whether disclosure of information regarding judges’ appointments and asset declarations would violate judicial independence and the right to privacy.
3. How to balance transparency with confidentiality and independence of the judiciary.

Judgment:

The Constitution Bench dismissed the appeal and held:

1. CJI’s Office under RTI:
   • The office of the Chief Justice of India is a “public authority” under Section 2(h) of the RTI Act.
   • Transparency applies equally to the judiciary as to other organs of the State.
   • Right to information and right to privacy must be balanced on a case-to-case basis.

Ratio Decidendi:

• The Office of the Chief Justice of India is a public authority under RTI Act.
• Transparency and judicial independence are complementary, not conflicting.
• RTI requests involving judges’ personal information (like assets) must balance public interest with privacy rights.

Significance of the Case:

• This judgment is a landmark in promoting judicial accountability in India.
• Reinforced that no constitutional authority, including the judiciary, is above the principles of transparency.
• It clarified that RTI Act applies to the Supreme Court and the Office of the CJI.

 Finally, The Supreme Court held that the CJI’s office is not beyond the scope of the RTI Act, and judicial transparency must coexist with independence and privacy.