News Citation : 2026 LN (HC) 54
Bilaspur, January 16, 2026 : The Chhattisgarh High Court has ruled that information relating to the service records of judicial officers, including educational and job-related certificates, complaints, and details of departmental or other inquiries, is exempt from disclosure under the Right to Information Act, 2005.
A Bench of Justice Sachin Singh Rajput held that such records constitute “personal information” and are protected from disclosure under Section 8(1)(j) of the RTI Act. The Court observed that these records are maintained by the High Court in its capacity as employer and are governed by service rules. Disclosure, the Court said, has no direct nexus with any public activity or demonstrable public interest.
The ruling came while allowing a batch of writ petitions filed by the administrative side of the High Court, represented through the Registrar General and Public Information Officers, challenging a 2019 order of the Chhattisgarh State Information Commission (SIC).
The dispute arose from an RTI application filed in 2017 by a private individual seeking details of complaints made against three judicial officers, the inquiries conducted into those complaints, and the certificates submitted by them at the time of appointment. The application was initially rejected by the Public Information Officer and the First Appellate Authority.
In January 2019, however, the State Information Commission allowed the second appeal and directed the High Court administration to furnish the information. Aggrieved by this direction, the High Court administration approached the High Court through writ petitions, which were heard together and decided by a common order.
Upholding the High Court’s challenge, the Bench held that service-related records of judicial officers are confidential in nature and disclosure would amount to an unwarranted invasion of privacy. The Court emphasized that the relationship between the High Court and judicial officers is fiduciary, attracting the protection of Section 8(1)(e) of the RTI Act. Complaints, inquiry records, and certificates, the Court said, are submitted in confidence and cannot be disclosed unless an overriding public interest is clearly established.
The Court noted that a plain reading of the RTI application did not indicate any public purpose behind the request. Instead, it appeared to be sought for the personal use of the applicant. In the absence of any demonstrated larger public interest, the exemption under the RTI Act squarely applied.
The High Court rejected the argument that the SIC’s order was invalid because it had been passed by a single Information Commissioner. It clarified that individual commissioners are legally competent to hear and decide appeals independently, as the RTI Act permits internal allocation of work among commissioners. A decision by a single commissioner, the Court held, does not amount to lack of jurisdiction.
The Bench also dismissed the contention that the SIC had ordered a roving inquiry. It observed that the information sought already existed with the High Court as the repository of service records and that the Commission had not directed creation of any new information.
Concluding that the information sought fell squarely within the exemptions under Sections 8(1)(e) and 8(1)(j) of the RTI Act, the Court quashed the SIC’s directions and allowed all the writ petitions.
Case Reference : WPC No. 1707 of 2012, High Court of Chhattisgarh and Another vs Rajkumar Mishra and Another. Counsels : For Petitioners : Shri Amrito Das, Shri Abhijeet Mishra and Shri Yashraj Verma, Advocates For Respondent – CGSIC : Shri Shyam Sunder Lal Tekchandani, Advocate