High Court of Bombay at Goa Quashes Order of State Chief Information Commissioner in RTI Case — Personal Information of Public Servant Exempt from Disclosure Under Section 8(1)(j) of Right to Information Act, 2005 unless Larger Public Interest Demonstrated. Information Regarding Date of Appointment, Educational Qualifications, Working Hours Relates to Personal Sphere and Disclosure Would Cause Unwarranted Invasion of Privacy.

Lawtext: Goa: Friday, 9^th October 2026.

Case Note & Summary: The matter arose from a writ petition under Article 227 of the Constitution of India filed by Deepak Pandharinath Vaingankar, a public servant, challenging an order dated 5 July 2018 passed by the State Chief Information Commissioner under the Right to Information Act, 2005. The dispute centered on whether personal information of the petitioner, including his date of appointment, working hours, educational qualifications, and other details, could be disclosed to the respondent No.1, Suryakant Babu Naik, under the RTI Act.
The respondent No.1 had filed an application under Section 6(1) of the Act seeking the petitioner's personal particulars. The Public Information Officer initially declined the information on 11 October 2017, finding that the application was motivated by personal harassment and lacked public interest. The First Appellate Authority dismissed the respondent No.1's first appeal on 4 January 2018. However, on a second appeal, the State Chief Information Commissioner allowed the disclosure on 5 July 2018, directing the Public Information Officer to furnish the information. Aggrieved, the petitioner approached the High Court.
The petitioner contended that the information sought was personal in nature, had no relationship to any public activity or interest, and would cause unwarranted invasion of privacy, thus being exempt under Section 8(1)(j) of the RTI Act. He relied on Supreme Court decisions in Girish Ramchandra Deshpande v. Central Information Commissioner and Canara Bank v. C.S. Shyam. The respondent No.1 argued that no reason was required to be given for seeking information under Section 6(2), and that under the proviso to Section 8(1)(j), information that could be disclosed to Parliament or State Legislature could also be disclosed to a citizen.
He also raised a procedural point regarding notice under Section 11. The High Court examined the relevant provisions of the RTI Act, including Sections 2(f), 2(h), 2(j), 6, 8(1)(j), and 11. It held that personal information of an employee, such as appointment date, educational qualifications, and working hours, falls within the expression 'personal information' in Section 8(1)(j) and is exempt from disclosure unless the authority is satisfied that larger public interest justifies it.
The  court found no such larger public interest was demonstrated. It further held that the mere fact that information could be disclosed to Parliament or State Legislature did not entitle a citizen to access it. The court quashed the order of the State Chief Information Commissioner, allowing the writ petition and upholding the exemption. The decision affirmed the principle that personal details of a public servant, unrelated to public activity, are protected from disclosure under the RTI Act to prevent unwarranted invasion of privacy.