Issues: Whether inspection of all orders passed by the Appellate Tribunal for Foreign Exchange could be denied on the ground that the applicant had not shown public interest; whether inspection of the despatch registers, reserved-and-unpronounced cases, and cause lists should be furnished; and whether the public authority should maintain centralized records for public scrutiny.

Issue (i): Whether inspection of all orders passed by the Appellate Tribunal for Foreign Exchange could be denied on the ground that the applicant had not shown public interest.

Analysis: Orders of a legally constituted authority are part of information ordinarily available in the public domain. Denial of access on the supposed ground that the applicant had not stated public interest was held to be unjustified. The refusal was found to be inconsistent with the obligations of the public authority under the Right to Information Act, 2005.

Conclusion: Disclosure of the orders was directed, and the denial was held to be unsustainable.

Issue (ii): Whether inspection of the list of cases reserved but not yet pronounced, and the cause lists, should be furnished.

Analysis: Information concerning hearings, reservation of orders, pronouncement of orders, and related cause lists was treated as part of the essential functioning of the public authority. The absence of any valid ground to withhold such information led to the conclusion that it should be centrally maintained and made available for inspection.

Conclusion: The information was directed to be furnished and the cause lists were directed to be made available.

Final Conclusion: The appeal succeeded to the extent that access to the requested records and lists was ordered, and the public authority was additionally advised to maintain a centralized, publicly accessible record of case-related information.

Ratio Decidendi: Information concerning the functioning and records of a public authority, including its orders and case-management details, cannot be withheld on the vague ground that the requester has not shown public interest when no specific exemption is established.

Issues: (i) Whether the information sought in the first two queries, being related to vigilance material and CVC advice, should be disclosed after the CPIO considers the matter under the Right to Information Act, 2005. (ii) Whether information relating to a completed vigilance proceeding against a third party could be withheld under section 8(1)(h) or section 8(1)(j) of the Right to Information Act, 2005.

Issue (i): The request concerned internal vigilance notes and the advice process involving the CVC. Disclosure was not finally denied on merits; instead, the CPIO was required to consult the CVC and take a decision by applying the Right to Information Act, 2005.

Analysis: The requested material was to be examined in the light of the advice already tendered by the CVC and the CPIO's own assessment of the statutory exemptions. The order therefore treated disclosure of these items as requiring a fresh administrative decision rather than outright refusal.

Conclusion: The CPIO was directed to consult the CVC and decide disclosure of the first two items within the time fixed.

Issue (ii): Whether vigilance information concerning a third-party employee, in a common matter where the proceeding against that third party had concluded but the proceeding against the appellant was still pending, could be denied under sections 8(1)(h) and 8(1)(j) of the Right to Information Act, 2005.

Analysis: Section 8(1)(h) was held to apply only so long as disclosure would impede an ongoing inquiry or investigation, and its protection ends when the proceeding is complete. Section 8(1)(j) was construed in the light of the privacy interest protected by the Act, but the order held that a departmental enquiry against a public employee is not purely personal information in the sense required for blanket exclusion. The decision emphasised that the disclosure request had to be assessed on a case-by-case basis, with the possibility of severing protected material under section 10(1) and considering confidentiality concerns under section 11(1).

Conclusion: The exemption claims under sections 8(1)(h) and 8(1)(j) were rejected for the completed third-party proceeding, and disclosure of the requested information was directed, subject to severance where necessary.

Final Conclusion: The appeal succeeded in substantial part, with disclosure ordered for the closed third-party vigilance material and a fresh decision directed on the remaining items.

Ratio Decidendi: Exemptions under sections 8(1)(h) and 8(1)(j) of the Right to Information Act, 2005 are not absolute and must be applied case by case; completed proceedings do not attract section 8(1)(h), and official vigilance inquiries into a public employee are not automatically exempt as personal information where larger public interest supports disclosure.

Issues: Whether the delay in transmitting and furnishing the requested information warranted imposition of penalty under the Right to Information Act, 2005.

Analysis: The information sought was not supplied within time, and the record showed delay in transmission as well as non-furnishing of part of the information for more than 100 days. The explanation that some information was not readily available did not eliminate the established delay in compliance.

Conclusion: Penalty under Section 20(1) of the Right to Information Act, 2005 was rightly imposed on the responsible officer.

Issues: Whether a requester under the Right to Information Act was required to establish public interest for seeking information, and whether the public authority was obliged to disclose the requested information proactively under its statutory disclosure obligations.

Analysis: The remarks made by the First Appellate Authority that the applicant had not shown a proper public purpose were held to be unwarranted. It was affirmed that the applicant was not required to prove public interest at the stage of seeking information. The decision further recognized that the information sought ought to have been disclosed suo motu by the public authority in accordance with its obligations of voluntary disclosure, which are intended to promote transparency and accountability in governance.

Conclusion: The objection based on absence of public interest was rejected, and the public authority was held bound to make the disclosure under its statutory duty of proactive disclosure.

Final Conclusion: The complaint was disposed of with a finding that the public authority had a statutory obligation to disclose the information proactively and that the applicant was not required to demonstrate public interest to seek it.

Ratio Decidendi: Under the Right to Information regime, a requester need not establish public interest to obtain information, and public authorities must proactively disclose information that falls within their statutory disclosure obligations.

Issues: (i) whether information held by a public authority could be denied on the ground that certified copies were obtainable through another statutory procedure; (ii) whether the existence of a separate copying or certified-copy mechanism could override disclosure under the Right to Information Act.

Issue (i): whether information held by a public authority could be denied on the ground that certified copies were obtainable through another statutory procedure.

Analysis: The expression "held" in Section 2(j) of the Right to Information Act was construed in its ordinary sense as meaning in possession of, and not as "withholding" or "not giving". The availability of certified copies under Section 76 of the Indian Evidence Act did not by itself justify refusal of information. In the absence of any specific order of a court forbidding disclosure or any exemption under the Right to Information Act, the public authority could not refuse access on the theory that disclosure would amount to contempt or that the information was otherwise obtainable.

Conclusion: The denial on this ground was unsustainable and the information could not be refused merely because certified copies were available under another law.

Issue (ii): whether the existence of a separate copying or certified-copy mechanism could override disclosure under the Right to Information Act.

Analysis: Section 22 of the Right to Information Act gives the Act overriding effect over inconsistent laws. The existence of another route for obtaining copies does not take away the citizen's right to choose the Right to Information Act, and the authority cannot impose a restriction not found in the statute. Since no exemption under the Act was established, the information had to be supplied.

Conclusion: The Right to Information Act prevailed, and the requested information was required to be furnished.

Final Conclusion: The refusal was set aside and the appellant was entitled to complete disclosure free of cost.

Ratio Decidendi: Where no exemption under the Right to Information Act is established, information in the possession of a public authority cannot be denied merely because an alternative statutory method exists for obtaining certified copies, and the Act overrides any inconsistent restriction in other laws.

Issues: (i) Whether annual property returns filed by government employees were exempt from disclosure under Section 8(1)(j) of the Right to Information Act. (ii) Whether copies of property returns of Group 'C' employees could be supplied when such returns were not shown to be on record and were stated not to be required under the applicable conduct rules.

Issue (i): Whether annual property returns filed by government employees were exempt from disclosure under Section 8(1)(j) of the Right to Information Act.

Analysis: The information sought related to annual property returns of government employees. The Commission treated such returns as information in the public domain and held that their disclosure could serve public accountability and help detect unexplained assets. On that view, the privacy exemption under Section 8(1)(j) was not accepted as a bar to disclosure for the returns that were available with the public authority.

Conclusion: The information was held disclosable and the request was allowed to that extent.

Issue (ii): Whether copies of property returns of Group 'C' employees could be supplied when such returns were not shown to be on record and were stated not to be required under the applicable conduct rules.

Analysis: The Commission accepted the respondent's position that the relevant conduct rules required annual returns from employees in Group 'A' and Group 'B', and that the requested Group 'C' returns were not available on record. Since the documents were not available with the authority, there was no basis for directing their supply.

Conclusion: The request for Group 'C' employees' property returns was rejected.

Final Conclusion: Disclosure was directed for the available property returns, but no direction was issued for records not held by the public authority.

Ratio Decidendi: Information contained in annual property returns of government employees may be treated as disclosable public information where no valid exemption applies, but a public authority cannot be compelled to furnish records that are not required to be maintained or are not available on its record.