The Central Information Commission has upheld the Puducherry Police’s decision to deny detailed recruitment records relating to Sub-Inspector appointments, holding that the information sought was largely third-party personal data protected under the Right to Information Act, 2005. CIC 2
Information Commissioner Vinod Kumar Tiwari delivered a common order on 19 November 2025 in two second appeals filed by P Irissane against the Public Information Officer, Superintendent of Police (Headquarters), Puducherry. The matters were heard on 17 November 2025 and clubbed because they involved the same parties and similar RTI queries about Sub-Inspector of Police recruitment from 1990 to 2013.
In the first RTI application dated 31 January 2024, the appellant asked for year-wise details of Sub-Inspector appointments in Puducherry, including:
- Names and present designations of officers appointed on compassionate grounds from 1990 to 2011.
- The number of Sub-Inspectors recruited on compassionate grounds between 2001–2010 and 2011–2013, with names and addresses.
- Year-wise figures of direct recruit Sub-Inspectors from 1990–2000 and 2001–2013.
- Details of Sub-Inspectors appointed under ex-servicemen and meritorious sportsperson quotas, with names and years of recruitment.
In the second RTI application filed the same day, he sought copies of selection committee minutes for direct recruitment to the post of Sub-Inspector between 1990–2000 and 2001–2012, as well as name-wise lists of candidates appointed on compassionate grounds between 2001–2013.
The appellant told the Commission that he was seeking the information “on behalf of SC/ST candidates” who had applied for these posts but were not selected, and argued that the authorities had failed to share complete records and supporting documents.
The PIO replied on 29 February 2024 in both matters. For recruitment prior to 2001, the PIO stated that no records were available. For later years, the office provided aggregate figures of direct recruitment, including a table that records 19 Sub-Inspectors appointed in 2003, 19 in 2004, 19 in 2007, 40 in 2011 and one compassionate appointment in 2012. The order also records the names of a few Meritorious Sports Persons and ex-servicemen recruited through direct recruitment in 2007 and 2011.
On compassionate appointments, the PIO initially stated that no Sub-Inspector was appointed on compassionate grounds between 2001 and 2011, and that one candidate, P. Pradaban, was appointed under that category in November 2012. At the first appeal stage, the First Appellate Authority additionally clarified that Chinta Kodhandaram, currently Superintendent of Police on current duty charge, had originally been appointed as a Sub-Inspector on compassionate grounds in February 1991.
With regard to the selection committee minutes sought in the second RTI, the PIO refused disclosure by invoking section 8(1)(e) of the RTI Act, arguing that the minutes and candidate particulars were held in a fiduciary capacity.
The First Appellate Authority upheld the PIO’s replies in both cases on 9 April 2024.
In the second appeal, the appellant maintained that the replies were incomplete and that crucial documents had been withheld without justification. He specifically challenged the reliance on section 8(1)(e) to deny copies of selection minutes and lists of compassionate appointees.
The PIO, appearing through video conference, relied on written submissions and contended that all permissible information had already been shared. He further submitted that the appellant himself was not an applicant for the Sub-Inspector posts, and that the data now sought related to the personal information of other candidates. On this basis, he argued that section 8(1)(j) of the RTI Act, which protects personal information of third parties from unwarranted invasion of privacy, was attracted.
The Commission also noted that proof of service of the second appeal on the respondent was not available on record and that the respondent confirmed non-service. To address this, the Information Commissioner directed that a copy of the PIO’s latest written submissions, along with enclosures, be supplied to the appellant free of cost and that proof of service be uploaded on the CIC portal.
After examining the file and hearing both sides, the Commission held that the replies already given by the PIO and supplemented through written submissions were in line with the RTI Act and required no interference. The order records that the information sought largely related to third-party candidates and their recruitment details, which fall within the scope of “personal information” protected under section 8(1)(j).
To support this, the Commissioner relied on the Supreme Court’s decision in Central Public Information Officer, Supreme Court of India v. Subhash Chandra Agarwal (2019), where the court consolidated earlier rulings in Canara Bank v. C.S. Shyam, Girish Ramchandra Deshpande v. CIC, and R.K. Jain v. Union of India. The judgment clarifies that personal records such as marks, grades, professional evaluations, disciplinary records, and financial and asset details are personal information, disclosure of which is subject to a larger public interest test.
Quoting that line of authority, the Commission reiterated that recruitment-related details tied to identifiable individuals, including names and selection committee assessments, are personal information. Since the appellant had not demonstrated any overriding public interest and was not himself a candidate in the recruitment processes, the Commission accepted the PIO’s stand that the information was exempt from disclosure.
While dismissing the second appeals, the Commission issued a limited direction in the “spirit of the RTI Act” that the PIO must share a copy of his most recent written submissions and annexures with the appellant within one week of receiving the order, free of cost, and upload proof of service on the CIC portal.
Case Details : P Irissane vs PIO, Superintendent of Police (HQ), Daman Street, Police Head Quarters, Puducherry – 605001
