The Delhi High Court has set aside an order of the Central Information Commission (CIC) which had directed disclosure of an individual’s income tax details to his estranged spouse and held that such personal financial information cannot be disclosed under RTI in the absence of any larger public interest.
The bench of Justice Purushaindra Kumar Kaurav clarified that the RTI Act is primarily intended to promote transparency in the functioning of public authorities and not to facilitate access to private information between individuals. It observed that the concept of “larger public interest” cannot be stretched to include private disputes such as matrimonial conflicts, as doing so would defeat the very purpose of the privacy protections built into the statute.
The petitioner, the husband, had challenged the CIC’s order dated July 22, 2021, which directed the disclosure of his net taxable income from FY 2007-08 onwards in response to an RTI application filed by his wife amid ongoing matrimonial proceedings.
The dispute arose in the backdrop of a maintenance claim filed by the wife. She had sought access to the petitioner’s income details through the RTI mechanism, arguing that such information was necessary to effectively pursue her claim. The CIC had accepted this contention and directed disclosure, prompting the husband to approach the High Court.
Before the Court, the petitioner contended that his income tax details constitute “personal information” exempt from disclosure under Section 8(1)(j) of the RTI Act, 2005, and that sharing such data would amount to an unwarranted invasion of privacy. On the other hand, the respondent-wife argued that she had a legitimate interest in accessing the information to secure appropriate maintenance.
The High Court, however, sided with the petitioner and emphasized that income tax returns and related financial details are inherently personal in nature. Relying on the Supreme Court’s ruling in Girish Ramchandra Deshpande v. CIC, the Court reiterated that such information is protected under the exemption clause of Section 8(1)(j) unless disclosure is justified by a larger public interest.
The Court rejected the argument that disclosure under RTI was necessary for adjudicating the maintenance claim. It pointed out that the legal framework already provides an appropriate mechanism for this purpose. Referring to the Supreme Court’s decision in Rajnesh v. Neha, the Court noted that both parties in maintenance proceedings are required to file affidavits disclosing their income, assets, and liabilities before the concerned court.
Thus, the Court held that the respondent-wife is not without remedy and can seek disclosure of financial details through the prescribed judicial process rather than invoking the RTI Act.
Concluding that the CIC’s direction amounted to an unjustified invasion of privacy and did not meet the threshold of “larger public interest,” the High Court declared the impugned order legally unsustainable and set it aside. The writ petition was accordingly disposed of, with liberty granted to the parties to pursue remedies available under matrimonial law.
Case Details
Case Title: Kapil Agarwal Versus CPIO Income Tax Officer Moradabad & Anr.
Citation: JURISHOUR-1060-HC-2026(DEL)
Case No.: W.P.(C) 8481/2021 & CM APPL. 26235/2021
Date: 28/04/2026
Counsel For Appellant: Vineet Sinha
Counsel For Respondent: Manish Raghav
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