Disclosure in adjudication must be decided separately from RTI proceedings; pending RTI cannot bar access or an additional reply.

A request for disclosure of investigation note-sheets and internal correspondence in adjudication must be decided on its own merits, and not by reference to a pending Right to Information application. If any portion of the requested material is withheld, reasons must be recorded. The pendency of an RTI proceeding cannot justify refusal of disclosure or denial of an opportunity to file an additional reply to the show cause notice. The order conflating the two distinct processes was therefore set aside, and the matter was remitted for fresh decision in accordance with law.

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Issues: Whether the Commissioner was justified in refusing disclosure of the requested investigation documents and in declining time for an additional reply to the show cause notice on the ground that an application under the Right to Information Act was pending.

Analysis: The Commissioner was required to decide the request for disclosure on its own merits, namely whether the note-sheets and internal correspondence sought by the noticee should be furnished at all, and if any part could lawfully be withheld, reasons had to be recorded. The pendency or possible outcome of an RTI application had no bearing on the separate question of disclosure in the adjudication proceeding. Once the disclosure issue was wrongly conflated with the RTI request, the consequential refusal to grant an opportunity to file an additional reply also stood on an erroneous basis.

Conclusion: The refusal to treat the RTI application as relevant to disclosure and further reply was incorrect, and the Commissioner's order was liable to be set aside with liberty to re-adjudicate the matter.

Final Conclusion: The writ petition succeeded, the impugned order was annulled, and the matter was sent back for fresh decision in accordance with law.

Ratio Decidendi: A request for disclosure of documents in adjudication must be decided independently of any RTI application, and a pending RTI proceeding cannot be used to deny disclosure or an opportunity to file an additional reply.

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