RTI Act: Litigant’s Private Need for Police Records Cannot Be Disguised as ‘Larger Public Interest’, Punjab and Haryana High Court Declines Disclosure of Third-Party Information

Case Name: Pavitar Singh v. Punjab State Information Commission and Others

Date of Judgment: September 7, 2026

Citation: CWP No. 28771 of 2026

Bench: Hon’ble Ms. Justice Kirti Singh

Held: The Punjab and Haryana High Court held that Section 6(2) of the Right to Information Act, 2005 merely relieves an applicant from disclosing the reasons for seeking information; it does not confer an unrestricted right to obtain information otherwise exempt under Section 8 of the Act. Information does not become disclosable merely because it is held by a public authority. Its nature and contents must be examined, particularly where the request covers an entire police action record containing information relating to a complainant and other persons connected with criminal proceedings.

The Court further held that a litigant’s requirement for documents in pending civil proceedings does not, without anything more, constitute “larger public interest” capable of overriding the exemption applicable to third-party information under Section 8(1)(j). The possible usefulness of information for advancing an applicant’s case in separate litigation remains a private requirement and cannot automatically be elevated into a matter of larger public interest.

The High Court also reiterated that, while exercising jurisdiction under Articles 226 and 227 of the Constitution against an order of the State Information Commission, it does not act as an appellate authority. Interference is warranted only where the Commission’s order suffers from a patent error of law, perversity, jurisdictional infirmity, non-application of mind or violation of the principles of natural justice.

Summary: The petitioner approached the Punjab and Haryana High Court challenging an order dated August 5, 2026 passed by the Punjab State Information Commission. The Commission had declined to direct disclosure of information sought by the petitioner concerning FIR No. 0093 dated November 22, 2024, registered at Police Station Kheri Gandian, District Patiala.

Through his RTI application, the petitioner sought copies of all actions taken by the Police Department and the Government of Punjab from the filing of the complaint and registration of the FIR until the date of furnishing the information. He subsequently preferred a first appeal and then a second appeal before the State Information Commission after the information was not supplied within the prescribed period.

The police authorities opposed disclosure on the ground that the requested material constituted third-party information protected under Section 8(1)(j) of the RTI Act. Material placed before the Commission indicated that a settlement had been reached between the concerned parties and that the petitioner was neither the complainant nor an accused in the FIR. On that basis, the Commission declined disclosure and disposed of the second appeal.

Before the High Court, the petitioner argued that information regarding action taken by public authorities pursuant to an FIR could not be treated as private merely because he was not named in the criminal case. He relied upon Section 6(2) of the RTI Act and asserted that the information was relevant to pending civil proceedings concerning the disputed land.

Rejecting these submissions, the Court observed that the application was not confined to a copy of the FIR or any specific document that was evidently public in nature. Instead, it sought the entire action-taken record, which could contain personal information relating to the complainant and other persons involved in the criminal proceedings. Accordingly, the Commission was justified in examining the actual nature and contents of the requested information.

The Court found that the Commission had considered the petitioner’s status in relation to the FIR, the objection raised by the police authorities, the nature of the requested information and the reported settlement between the concerned parties. No patent illegality, perversity or jurisdictional infirmity was established. The Court clarified that it had expressed no opinion on the underlying land dispute, the allegations in the FIR, the pending civil proceedings or the purported settlement.

Decision: The High Court dismissed the writ petition and declined to interfere with the order passed by the Punjab State Information Commission.