New Delhi: The Delhi Excessive Courtroom dominated on Monday that educational data are “private data” exempt from the Proper to Data Act (RTI) until instructional {qualifications} are a prerequisite or an eligibility criterion for public workplace, contradicting a 2016 Central Data Fee (CIC) order that successfully directed the disclosure of details about Prime Minister Narendra Modi’s diploma from Delhi College.

The 25 August 2025 Delhi Excessive Courtroom ruling units apart the nine-year-old CIC order that allowed an RTI (Proper to Data) applicant to look at Delhi College data of scholars who accomplished the Bachelor of Arts (BA) programme again in 1978, when Modi says he graduated his bachelor’s. In 2016, the CIC successfully allowed the inspection of DU scholar data for extra readability on Modi’s diploma.

Part 8(1)(j) of the Act exempts data that’s “private” and has “no relationship to any public exercise or curiosity” or would trigger “unwarranted invasion of privateness”. The one circumstance beneath which such data could also be disclosed is that if “bigger public curiosity” justifies it.

Calling the CIC’s method in its 2016 order “completely misconceived”, the court docket added that data regarding a level, marks or outcomes of any particular person isn’t within the nature of “public data”, citing a 2020 Supreme Courtroom ruling in Central Public Data Officer vs. Subhash Chandra Agarwal.

The court docket mentioned the state of affairs would have been totally different if instructional {qualifications} had been a prerequisite for eligibility to a particular public workplace. It added that non-public data can solely be disclosed whether it is wanted within the public curiosity to make sure transparency and accountability within the public employment choice course of.

The court docket relied on earlier SC rulings to say that Part 8 of the RTI Act seeks to steadiness conflicting pursuits. On one hand, it goals to result in transparency and accountability by offering entry to data beneath the management of public authorities; on the opposite, it goals to make sure that the confidentiality of delicate data isn’t jeopardised.

Emphasising that the connection between Delhi College and its college students is characterised by belief and an obligation to behave within the college students’ finest curiosity, the court docket famous that the college is obligated to situation outcomes, by marksheets or transcripts, solely to the scholars involved and to not any third social gathering or the general public.

“The framework doesn’t allow the disclosure of marks/grades to any third social gathering. There’s an implicit responsibility of belief and confidentiality in dealing with college students’ educational data,” it famous in its order.

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Arguments on Modi’s diploma

Representing Delhi College, Solicitor Basic of India Tushar Mehta argued that the Modi’s diploma could possibly be proven to the court docket, however to not the general public at giant, merely to serve the pursuits of people who’re looking for publicity or are pushed by public motives.

Searching for to put aside the 2016 order, Mehta argued that disclosure of the data wouldn’t be within the public curiosity to fulfill the “curiosity of others”. The legislation isn’t without cost people who find themselves out to “fulfill their curiosity or embarrass others”, he had mentioned.

Then again, senior advocate Sanjay Hegde, who appeared for Neeraj, the RTI applicant who filed the plea, argued that the 2005 Act allowed for disclosure of data, corresponding to Modi’s diploma, within the larger public curiosity. He contended that such data would usually be printed by Delhi College on its discover boards, web site, and even newspapers.

Origins of the case

On 21 December 2016, the CIC—an appellate physique constituted beneath the RTI Act, 2005—handed an order primarily based on the RTI software by activist Neeraj, permitting for the inspection of scholars’ data for the BA programme’s batch of 1978.

The Delhi Excessive Courtroom quickly stayed the CIC order on 23 January 2017, after the college challenged it earlier than a bench of Justice Sanjeev Sachdeva.

Delhi College argued that each one such data is held in a fiduciary capability, and mere curiosity with none demonstrable public curiosity doesn’t justify the disclosure of such data beneath the RTI Act.

Arguments went on after the CIC order was stayed in 2017. The court docket reserved its orders within the case in February this yr after listening to the arguments.

In its 175-page ruling delivered on Monday, the court docket additionally acted on a petition filed by one Mohammad Naushadudin beneath the RTI Act, looking for data from the Central Board of Secondary Schooling (CBSE), about whether or not former minister and Kyunki Saas Bhi Kabhi Bahu Thi 2 actress Smriti Irani cleared the matriculation examination in 1991 and the intermediate examination in 1993 from CBSE.

In January 2017, the CIC directed the CBSE to facilitate the inspection of related data and supply licensed copies of paperwork to the appellant.

“The excuse of the sensible problem in looking out from large quantity of data for the yr 1991 and 1993 to furnish the data sought by the appellant isn’t legitimate,” the CIC mentioned whereas directing that the RTI applicant be equipped with the paperwork.

On Monday, nevertheless, the court docket additionally put aside this 2017 order.