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

1. The present intra-court appeal has been preferred by the Appellant assailing the judgment dated 06.05.2026 (“Impugned Judgment”) passed in W.P.(C) 14827/2025 (“Writ Petition”), whereby the learned Single Judge dismissed the Writ Petition instituted by the Appellant seeking quashing of the order dated 28.07.2025 passed by the Central Information Commission (“CIC”) in Second Appeal No. CIC/CBRUI/A/2024/126536 (“CIC Order”).

2. The Appellant had sought disclosure of the recorded statements of seven property owners/occupants, which were relied upon by the Appellant to substantiate the allegations of blackmailing against the Appellant and his father in the self-contained note dated 16.10.2019 forwarded by the Central Bureau of Investigation (“CBI”) to the Commissioner of Police, Delhi Police, for appropriate action.

3. Disclosure of the said information was declined by the Central Public Information Officer, CBI (“CPIO”) vide its response dated 30.04.2024, and subsequently by the CIC vide the CIC Order, on the ground that the information squarely fell within the exemption contained in Section 8(1)(g) of the Right to Information Act, 2005 (“RTI Act”). Aggrieved by the CIC Order, the Appellant instituted the Writ Petition before this Court.

4. Vide the Impugned Judgment, the learned Single Judge by relying upon the exemption under Section 8(1)(g) of the RTI Act dismissed the Writ Petition. Being aggrieved thereby, the Appellant has preferred the present Appeal.

5. It is the case of the Appellant that the learned Single Judge failed to appreciate that the exemptions under the RTI Act, including Section 8(1)(g), are required to be construed narrowly. The Appellant further submitted that the exemption was applied mechanically by the learned Single Judge, without examining the nature or likelihood of the apprehended harm. It was also contended that the Respondents had failed to establish any tangible threat to the life or safety of the said property owners/occupants.

6. The gravamen of the Appellant’s contention is that the learned Single Judge erred in placing reliance upon Section 8(1)(g) of the RTI Act in the facts and circumstances of the present case. In this regard, it would be apposite to refer to Section 8(1)(g) of the RTI Act, which reads as under: “Section 8. Exemption from disclosure of information. […] (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; […]”

7. A plain reading of Section 8(1)(g) of the RTI Act makes it evident that any information furnished in confidence for law enforcement purposes, or disclosure whereof is likely to endanger the life or physical safety of any person, is exempt from disclosure. Accordingly, we are of the view that CPIO, CIC and the learned Single Judge were right on concurrently denying the disclosure of the information sought by the Appellant.

8. The learned Single Judge also rightly placed reliance upon the decision of the Supreme Court in Bihar Public Service Commission v. Saiyed Hussain Abbas Rizwi, (2012) 13 SCC 61, wherein it was held that the expression “life” occurring in Section 8(1)(g) of the RTI Act must receive a liberal construction. It was further held in Bihar Public Service Commission (supra) that the competent authority, namely the CPIO in the present case, is entitled to assess whether disclosure of the information is likely to endanger the life or physical safety of any person and, accordingly, to bring such information within the exemption contemplated under Section 8(1)(g) of the RTI Act.

9. In the present case, the allegations of blackmailing against the Appellant are founded upon the statements of the aforesaid property owners/occupants, which were furnished in confidence to the CBI. Disclosure of the names or other identifying particulars of such individuals may reasonably endanger their life or physical safety.

10. In these circumstances, the invocation of the exemption under Section 8(1)(g) of the RTI Act was entirely justified. Therefore, there is no infirmity found in the Impugned Judgment warranting any interference in the present Appeal. Accordingly, the present Appeal is dismissed. Pending application(s), if any, also stand disposed of. There shall be no order as to costs.

TEJAS KARIA, J DEVENDRA KUMAR UPADHYAYA, CJ JULY 20, 2026 St