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R.K. Jain v. Union of India

R.K. Jain v. Union of India (Supreme Court of India, 2013-04-16) (2013) 14 SCC 794 is a ruling on the Right to Information Act, 2005 — Sections 8(1)(i), 10. File noting is not Cabinet papers; post-decisional disclosure mandatory. Section 8(1)(i) exemption is limited to Cabinet-level deliberations of the Council of Ministers, Secretaries and other officers.

Holding

File noting is not Cabinet papers; post-decisional disclosure mandatory.

Ratio

Section 8(1)(i) exemption is limited to Cabinet-level deliberations of the Council of Ministers, Secretaries and other officers. Routine departmental file noting at Section Officer / Under Secretary level is administrative record and disclosable. The proviso to §8(1)(i) mandates post-decisional disclosure.

Section(s) applied

Practitioner takeaway

§8(1)(i) protects only Cabinet-level deliberation; routine file noting disclosable.

Citation

Last reviewed: 23 April 2026.