RTI disclosure of vigilance records turns on completed inquiry status, privacy limits, and case-by-case exemption review.

Vigilance material and CVC advice may be reconsidered by the CPIO before disclosure under the RTI Act, rather than being refused outright. For completed third-party vigilance proceedings, section 8(1)(h) does not apply once the inquiry is over, and section 8(1)(j) does not create a blanket bar where the material concerns a public employee's departmental enquiry. Disclosure must be assessed case by case, with severance of protected portions under section 10(1) and confidentiality considerations under section 11(1) where needed.

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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.

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