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Reserve Bank of India v. Jayantilal N. Mistry

Reserve Bank of India v. Jayantilal N. Mistry (Supreme Court of India, 2015-12-16) (2016) 5 SCC 136 is a ruling on the Right to Information Act, 2005 — Sections 8(1)(d), 8(1)(e), 8(2). §8(1)(e) fiduciary applies only in strict classical sense; regulator-regulated is not fiduciary. Section 8(1)(e) fiduciary exemption is confined to the strict classical fiduciary relationship — doctor-patient, lawyer-client, trustee-beneficiary, priest-penitent.

Holding

§8(1)(e) fiduciary applies only in strict classical sense; regulator-regulated is not fiduciary.

Ratio

Section 8(1)(e) fiduciary exemption is confined to the strict classical fiduciary relationship — doctor-patient, lawyer-client, trustee-beneficiary, priest-penitent. The relationship between RBI and the regulated bank is not fiduciary. Bank inspection reports and willful-defaulter lists must be disclosed where public interest is involved.

Section(s) applied

Practitioner takeaway

Bank inspection reports + defaulter list disclosable; PI override applies.

Citation

Last reviewed: 23 April 2026.