CBSE v. Aditya Bandopadhyay
Rule established
Evaluated answer sheets are 'information' under RTI Act S.2(f) and can be disclosed; but RTI should not be used to paralyze administration
Facts
- Aditya Bandopadhyay (student) sought copy of his evaluated CBSE answer sheet under RTI Act
- CBSE refused: argued answer sheets are "fiduciary" information (S.8(1)(e)) and disclosure would disrupt examination system
- Central Information Commission directed disclosure
- CBSE appealed to courts
Issues
- Whether evaluated answer sheets constitute "information" under S.2(f) of RTI Act?
- Whether S.8(1)(e) (fiduciary relationship) exempts answer sheets from disclosure?
Held
- Answer sheets ARE "information" under S.2(f): "any material in any form" includes evaluated sheets
- Relationship between examiner and CBSE is NOT fiduciary; it is contractual/professional
- S.8(1)(e) does not apply; disclosure must be granted
- However: SC cautioned that RTI is a means to achieve good governance and transparency, not a tool to obstruct government functioning
- Directed reasonable fee for photocopying; discouraged mass/frivolous applications
Ratio Decidendi
The RTI Act's definition of "information" (S.2(f)) is extremely broad: "any material in any form held by a public authority." Evaluated answer sheets clearly fall within this. Exemptions under S.8 must be strictly construed (being exceptions to the fundamental right to know). The examiner-Board relationship is professional/contractual, not fiduciary (which requires highest obligation of trust like trustee-beneficiary).
How to use it in an exam
- Deploy in questions on RTI scope, meaning of "information," S.8 exemptions.
- Key line: "RTI is a powerful right. But every powerful right requires a responsible citizen. RTI should not be allowed to be used as a tool to obstruct the functioning of public authorities."
Source
Source: Massey, Administrative Law
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.