RTI public authority status affirmed for a State-statutory trust; board meeting records were not exempt from disclosure.

A body constituted under a State enactment and governed by a board created under that law falls within the definition of a public authority under Section 2(h) of the Right to Information Act, 2005. The agenda, resolutions and proceedings of the board meeting were held not to fall within any exemption under Section 8, so disclosure could not be withheld. The challenge to the disclosure orders therefore failed, and the writ petition was not sustainable.

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Issues: (i) Whether the petitioner-trust was a "public authority" within the meaning of the Right to Information Act, 2005. (ii) Whether the information sought was exempt from disclosure under the Act.

Issue (i): Whether the petitioner-trust was a "public authority" within the meaning of the Right to Information Act, 2005.

Analysis: The trust was constituted under a State enactment and its administration, management and governance were vested in a Board created by that law. A body constituted under a law made by the State Legislature falls within the statutory definition of "public authority" under Section 2(h) of the Right to Information Act, 2005.

Conclusion: The petitioner-trust is a public authority under Section 2(h) of the Right to Information Act, 2005.

Issue (ii): Whether the information sought was exempt from disclosure under the Act.

Analysis: The requested material comprised the agenda, resolutions and proceedings of the Board meeting. The information did not fall within any of the exemption categories enumerated in Section 8 of the Right to Information Act, 2005.

Conclusion: The information sought was not exempt from disclosure.

Final Conclusion: The challenge to the disclosure orders failed, and the writ petition was not sustainable.

Ratio Decidendi: A body constituted under a State statute is a public authority under Section 2(h) of the Right to Information Act, 2005, and information not covered by the exemptions in Section 8 must be disclosed.

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