Source: Punjab & Haryana High Court 

Why in News? 

Justice Harsimran Singh Sethi has held that the Right to Information Act, 2005 (RTI Act) was enacted to ensure transparency in departments, but it does not give anyone the right to seek information with a motive that amounts to harassment of department employees.   

• The Punjab & Haryana High Court has held in the matter of Punjab State Federation of Co-operative Sugar Mills Ltd. v. The State Information Commission, Punjab and another (2025). 

What was the Background of the Punjab State Federation of Co-operative Sugar Mills Ltd. v. The State Information Commission, Punjab and Another case? 

• On January 15, 2024, Plaintiff John Smith ("Smith") was operating his vehicle, a 2022 Honda Civic, eastbound on Main Street in Springfield. 
• At approximately 2:30 p.m., Defendant Mary Jones ("Jones") was operating her vehicle, a 2023 Toyota Camry, northbound on Oak Avenue. 
• The intersection of Main Street and Oak Avenue is controlled by traffic signals in all directions. 
• Smith alleges that he entered the intersection with a green light in his favor. 
• Jones contends that she also had a green light when entering the intersection. 
• The vehicles collided in the intersection, causing substantial damage to both vehicles and resulting in injuries to Smith. 
• Smith was transported via ambulance to Springfield General Hospital where he was diagnosed with a fractured wrist, cervical strain, and various contusions. 
• Smith incurred medical expenses in the amount of $42,875.00 and was unable to work at his employment as a carpenter for a period of twelve (12) weeks. 
• Prior to the collision, Jones had been at a business lunch where she consumed two alcoholic beverages. 
• A blood alcohol test administered to Jones approximately forty-five (45) minutes after the collision showed a blood alcohol concentration of 0.06%. 
• The Springfield Police Department Traffic Division investigated the accident and issued a citation to Jones for failure to obey a traffic signal. 
• Three witnesses to the collision provided statements to police.  
• Two witnesses indicated that Jones entered the intersection against a red light, while one witness stated that both vehicles entered the intersection simultaneously. 
• A writ petition was filed before the Punjab & Haryana High Court.

What were the Court’s Observations?

• The Punjab & Haryana High Court Observed that: 
  • The Right to Information Act, 2005 (RTI Act) was enacted to ensure transparency in departments, but it does not give anyone the right to seek information with a motive that amounts to harassment of department employees. 
  • The application sought third-party information regarding who competed for the purchase of Molasses, Baggasse, and Press Mud, which is barred under Rule 8 of the RTI Act. 
  • The Court observed that indiscriminate demands for disclosure of all information unrelated to transparency and accountability would be counter-productive and adversely affect administrative efficiency. 
  • The Court noted that the RTI Act should not be allowed to be misused or abused to become a tool of obstruction, oppression, or intimidation of honest officials. 
  • The Court observed that the complainant showed lack of interest in pursuing the remedy, as the matter had been pending for 10 years without efforts to uphold the impugned order. 
  • Regarding the second petition the Court observed that information relating to employees, works, and expenditure constituted personal information that is exempt from disclosure. 
  • The Court cited precedents from the Supreme Court of India [Canara Bank v. C.S. Shyam (2011) and CBSE vs. Aditya Bandopadhyay (2017)] to support its observations about limitations on disclosure of third-party and personal information. 

What is the RTI Act? 

About: 

• It is an act of the Parliament of India which sets out the rules and procedures regarding citizens' right to information. 
• Under the provisions of RTI Act, any citizen of India may request information from a public authority which is required to reply expeditiously or within thirty days. 
• The RTI Bill was passed by Parliament of India on 15 June 2005 and came into force with effect from 12th October 2005. 

Objectives: 

• To empower the citizens. 
• To promote transparency and accountability 
• To deal with corruption. 
• To enhance people’s participation in the democratic process.

Landmark Judgements 

• Central Board of Secondary Education v. Aditya Bandopadhyay (2011): 
  • The Supreme Court recognized the right to information as a "cherished right" and an important tool to fight corruption and bring transparency and accountability to public authorities. 
  • The Court emphasized that RTI provisions should be strictly enforced regarding information that relates to transparency, accountability, and discouraging corruption. 
  • However, the Court made an important distinction: for information other than that explicitly required to be disclosed under Section 4(1)(b) and (c) of the Act, equal importance must be given to other public interests, including: 
    • Confidentiality of sensitive information. 
    • Fidelity and fiduciary relationships. 
    • Efficient operation of governments. 
  • The Court warned against "indiscriminate and impractical demands" for disclosure of all information, as this would: 
    • Be counter-productive. 
    • Adversely affect administrative efficiency. 
    • Result in executives getting bogged down with non-productive work. 
  • The Court expressed concern that the Act should not be misused to: 
    • Obstruct national development and integration. 
    • Destroy peace and harmony among citizens. 
    • Become a tool of oppression or intimidation against officials doing their duty. 
  • The Court noted that the nation does not want a scenario where "75% of the staff of public authorities spends 75% of their time in collecting and furnishing information to applicants instead of discharging their regular duties." 
• Canara Bank v. C.S. Shyam (2017): 
  • The Court established that the performance of an employee in an organization is primarily a matter between the employee and employer, governed by service rules. 
  • Such information falls under "personal information," disclosure of which: 
    • Has no relationship to any public activity or public interest. 
    • Would cause unwarranted invasion of privacy of the individual. 
  • The Court specified that details such as memos issued to employees, show-cause notices, orders of censure/punishment, and income tax returns qualify as "personal information." 
  • The Court noted that such information could only be disclosed if: 
    • The Information Officer is satisfied that larger public interest justifies disclosure. 
    • The applicant can demonstrate such larger public interest. 
  • In the specific case, the Court found that: 
    • The information sought about individual bank employees was personal. 
    • It was exempted under Section 8(j) of the Act. 
    • The applicant did not disclose any public interest, much less a larger public interest, in seeking such information. 
    • Neither the Central Information Commission nor the High Court recorded any finding regarding larger public interest.