Pavit Singh v. Central Public Information Officer, Central Bureau of Investigation & Ors.

Delhi High Court · 06 May 2026 · 2026:DHC:4241
Purushaindra Kumar Kaurav
W.P.(C) 14827/2025
2026:DHC:4241
administrative petition_dismissed Significant

AI Summary

The Delhi High Court upheld the exemption under Section 8(1)(g) of the RTI Act, denying disclosure of confidential investigation statements to protect law enforcement interests and personal safety.

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HIGH COURT OF DELHI
W.P.(C) 14827/2025 and CM APPL. 60984/2025
Date of Decision: 06.05.2026 IN THE MATTER OF:
PAVIT SINGH .....Petitioner
Through: Ms. Karishma Maria, Advocate.
VERSUS
CENTRAL PUBLIC INFORMATION OFFICER, CENTRAL BUREAU OF INVESTIGATION & ORS. .....Respondents
Through: Mr. Ashish K Dixit, CGSC with Mr. Gautam Yadav , Mr. Umar Hashmi and Ms. Iqra Sheikh, Advocates for
R-UOI.
Mr Anupam S Sharrma (SPP CBI) with Ms. Harpreet Kalsi , Mr. Vashishth Rao , Ms. Amisha P dash , Mr. Abhiyant Singh , Mr. Mayank Tyagi , Ms Pragati Ojha, Advocates for R-CBI.
CORAM:
HON’BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
JUDGMENT
PURUSHAINDRA KUMAR KAURAV, J.
(ORAL)

1. The instant petition is for the following reliefs:-

“A. Issue a Writ in the nature of Certiorari or any other appropriate Writ, order or direction quashing and setting aside order dated 28.07.2025 passed by the Ld. Central Information Commission in Pavit KUMAR KAURAV Singh v. CPIO, Central Bureau of Investigation, New Delhi [Second Appeal No. CIC/CBRUI/A/2024/126536]; and
B. Pass such other or further order(s) as this Hon'ble Court may deem fit and proper in the facts and circumstances of the present case and in the interest of justice.”

2. Learned counsel appearing on behalf of the petitioner points out from the status report dated 09.05.2022 filed by the Central Bureau of Investigatin (‘CBI’) that the CBI had sent a Self-Contained Note to the Commissioner of Police, Delhi Police dated 16.10.2019 for taking action against the petitioner and his father on the ground that the allegations of blackmailing against them were substantiated by the recorded statements of seven property owners/occupants. The petitioner, thus, contends that the petitioner is entitled for the recorded statement or atleast names of purported seven property owners/occupants.

3. The information was denied by the Public Information Officer (‘PIO’) and the First Appeallate Authority. The Petitioner unsuccessfully challenged the order before the Second Appeallate authorities. Paragraph No.8 of the order dated 28.07.2025 passed by the Second Appeallate authoritiy, Central Information Commission (‘CIC’) is extracted as under:-

“8. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that the CPIO has given an appropriate reply and rightly claimed exemption U/s 8(1)(g) of RTI Act. Upon the Commission’s query on the appellant’s involvement in the issue therein, the Respondent submitted that the appellant’s role surfaced in the allegation of blackmailing on the basis of recorded statements of the aforesaid seven persons which was given to the Respondent in State confidence and since the seven persons statements were given under State confidence, the respondent claimed exemption U/s 8(1)(g) of RTI Act. With these observations, the Commission finds no scope of intervention in the matter. Accordingly, the appeal is dismissed.”

4. It thus, appears that Section 8(1)(g) of the Right to Information Act, 2005 (‘RTI Act’) has been invoked to deny the information. Section 8(1)(g) of the RTI Act is extracted as under:- “Section 8 (1)..... (g) information, the disclosure of which would endanger the life or physical safety of any person or identify the source of information or assistance given in confidence for law enforcement or security purposes;

5. A plain reading of the provision shows that information provided in confidence for law enforcement purposes is exempt from disclosure. The statements in question were given to the CBI by seven individuals in the course of a preliminary inquiry directed by this Court. As recorded in the status report filed by the CBI, these statements substantiated the allegations of blackmailing against the petitioner.

6. The Supreme Court in Bihar Public Service Commission v. Sayyed Hussain Abbas Rizvi[1] held that the expression life in Section 8(1)(g) must be construed liberally and that the authority is entitled to form an opinion on the likelihood of danger. The Court observed: “If in the opinion of the concerned authority there is danger to life or possibility of danger to physical safety, the CPIO would be entitled to bring such case within the exemption of Section 8(1)(g) of the RTI Act.”

7. The petitioner argues that he needs the statements to challenge their veracity. However, the RTI Act is not a substitute for criminal or civil remedies. It is meant for accessing information held by public authorities to promote transparency, and not for collaterally challenging investigation material. Under the guise of the RTI Act, these statements cannot be directed to be furnished.

8. The Court is of the view that the CPIO rightly invoked the exemption under Section 8(1)(g) and the CIC correctly upheld it. No ground for interference under Article 226 of the Constitution is made out. The Court, therefore, grants liberty to the petitioner to challenge the veracity or the existence of such statements in accordance with law.

9. With these observations, the instant petition along with the pending application stands disposed of.

PURUSHAINDRA KUMAR KAURAV, J MAY 6, 2026 Nc