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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.