New Delhi: The Delhi High Court on Monday quashed a 2016 order of the Central Information Commission (CIC) that had directed Delhi University (DU) to disclose details of Prime Minister Narendra Modi’s 1978 degree.

Upholding the stance of Delhi University, the court observed that a student’s academic records, including marks and degrees, fall within the ambit of “personal information” under the RTI Act and cannot be disclosed unless there is overriding public interest. It underlined the fiduciary relationship between a university and its students and said disclosure of such details would amount to an intrusion into privacy.

Justice Sachin Datta noted that DU’s statutes do not allow sharing of grades or marks with third parties and that students have a “legitimate expectation” of confidentiality.

“It is unambiguously clear that the ‘marks obtained’, grades, and answer sheets etc., are in the nature of personal information and protected under Section 8(1)(j) of the RTI Act, subject to an assessment of overriding public interest… This court cannot be oblivious to the reality that what may superficially appear to be an innocuous or isolated disclosure could open the floodgates of indiscriminate demands, motivated by idle curiosity or sensationalism, rather than any objective ‘public interest’ consideration,” Justice Datta stated in the order.

The court also referred to a similar 2023 Gujarat HC ruling that set aside a CIC order seeking Modi’s Gujarat University records. It further criticized the CIC for adopting a “misconceived” approach, stressing that the RTI Act promotes transparency in governance and is not meant to fuel sensationalism.

The bench dealt with six petitions, including four by DU. Among other issues, it set aside a CIC directive imposing a penalty on DU’s Central Public Information Officer (CPIO), stating that no mala fide intention was established. The court also noted the heavy RTI burden on DU, which receives over 2,000 applications annually, making penalty recovery from the CPIO’s personal salary “disproportionate.”

In a related case, the court similarly overturned a CIC order directing CBSE to provide copies of Smriti Irani’s academic records, holding that such information too is protected under Section 8(1)(j) of the RTI Act. DeshGujarat