Third-party income tax returns remain protected personal information absent objective proof of larger public interest.

Income tax returns of a third party were treated as personal information protected by Section 8(1)(j) of the Right to Information Act, 2005, and disclosure was not available as a matter of right. The Court held that such records may be disclosed only on an objectively recorded satisfaction that larger public interest overrides the privacy exemption. The petitioner's reliance on cross-checking election affidavits and broad allegations of corruption did not establish any specific public interest sufficient to justify disclosure, and the refusal to furnish the returns was upheld.

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Issues: Whether income tax returns of a third party are exempt from disclosure under the Right to Information Act, 2005, and whether the petitioner had shown a sufficient larger public interest to justify disclosure despite the privacy exemption.

Analysis: Section 8(1)(j) of the Right to Information Act, 2005 protects personal information where disclosure has no relationship to any public activity or interest or would cause unwarranted invasion of privacy, unless the competent authority is satisfied that larger public interest justifies disclosure. The Court applied the principle that income tax returns are personal information and that disclosure is not a matter of right. It relied on the Supreme Court's exposition that such information may be disclosed only on an objectively recorded satisfaction of larger public interest, and held that the petitioner's stated reason of cross-checking election affidavits and making general allegations about corruption did not demonstrate any specific public interest in disclosure of the third party's returns. The Court also held that the proviso to Section 8(1)(j) could not be read to mean that any information allegedly obtainable by Parliament or a State Legislature must automatically be furnished to a citizen, and distinguished the cases relied upon by the petitioner on their facts.

Conclusion: The income tax returns remained exempt from disclosure, and the refusal to furnish the information was upheld.

Final Conclusion: The writ petition failed because the requested income tax returns were held to be protected personal information and no larger public interest was established to override the privacy exemption.

Ratio Decidendi: Income tax returns constitute personal information under Section 8(1)(j) of the Right to Information Act, 2005, and can be disclosed only when the authority records objective satisfaction that larger public interest outweighs the privacy interest of the individual.

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