Service Records RTIs — A PIO Playbook

• Section 8(1)(j) — personal information exempt unless larger public interest.
• Section 8(2) — override.
• Section 10 — severability.
• Section 11 — third-party notice (officer is third party; always applicable).
• DPDP Rules, 2025 — strengthened privacy baseline.

1. Step 1. Is the RTI about the applicant's own service record? If yes, disclose (Aditya Bandopadhyay self-data principle).
2. Step 2. If third-party, classify the request per the matrix above.
3. Step 3. Issue Section 11 notice to the officer concerned — always applicable here.
4. Step 4. Consider public-interest override under §8(2). Genuine cases: vigilance petitioner, documented impropriety, misuse-of-position claim, public-servant-conduct concern.
5. Step 5. Apply §10 severability — redact PAN, Aadhaar, bank, phone, home address even in disclosable elements.
6. Step 6. Draft speaking reply with Deshpande citation if declining.

The RTI seeks [describe: APAR / medical leave / disciplinary file / etc.] of Shri/Smt X, [designation]. The officer is a third party; records have been treated as confidential by this Office.

Section 11(1) notice was issued on DD-MM-YYYY; objections received / no objection received.

Classification: The requested information relates to the personal service record of the officer. It is personal information under Section 8(1)(j) of the RTI Act, 2005. The Supreme Court in //Girish Ramchandra Deshpande v. CIC// (2013) 1 SCC 212 has held that APAR, service records, and disciplinary proceedings fall within §8(1)(j).

Balancing under §8(2): The applicant [has / has not] pleaded specific public interest. [If pleaded: analysis.] No larger public interest is demonstrated that would warrant disclosure.

Severability under §10: [No severable portion / Partial disclosure at Annexure A with PAN and bank details redacted].

Decision: [Decline / Partial disclosure].

• RTI for officer's travel bills. Disclosable — TA/DA is government spending. Redact PAN.
• RTI for officer's spouse's job status. Rarely disclosable — personal / family data unrelated to public function.
• RTI for officer's Property Returns. Section 8(1)(j) applies; CIC orders have held that officer's own disclosure obligations don't auto-translate to public access.
• RTI for pattern of transfers. Aggregate patterns disclosable; named-individual history case-by-case.
• RTI for disciplinary inquiry report. Pre-decisional — exempt. Final order — disclose.

• Girish Ramchandra Deshpande v. CIC (2013) 1 SCC 212 — core SC anchor.
• CBSE v. Aditya Bandopadhyay (2011) 8 SCC 497 — own data to self principle.
• CPIO, SC v. Subhash Chandra Agarwal (2020) 5 SCC 481 — proportionality for public offices.

• Disclosing APAR despite Deshpande.
• Skipping §11 notice because “officer is a colleague”.
• Denying own-service-record RTIs (self-data is disclosable).
• Missing §10 redaction of PAN/bank/phone.
• Over-citing Deshpande to deny pay-scale structure (which is notified and public).

• Build a one-page internal SOP for service-record RTIs; circulate to PIOs.
• Ensure HR module flags bank/PAN data for automatic redaction.
• Respond to vigilance-petitioner RTIs promptly; public-interest pleadings here are serious.

Q1. Can a family member file RTI for their relative's APAR?
Same rule. Relationship does not create entitlement. Self-data yes; third-party data needs §8(2) balancing.

Q2. Is officer's promotion-order disclosable?
Final promotion order — yes. DPC minutes — no.

Q3. Does retirement change anything?
No. Exemption continues; but public interest may be easier to establish in pension-related matters.

Service-record RTIs are the single most-litigated category. Deshpande-driven denials must be reasoned, balanced, and severable. Blanket “personal information” refusals rarely survive appeal.

• Section 8(1)(j) framework
• Section 11 third-party notice
• Privacy vs public interest balancing
• PIO & FAA knowledge base

• RTI Act, 2005, Sections 8(1)(j), 8(2), 10, 11
• Girish Deshpande, (2013) 1 SCC 212

Last reviewed: 21 April 2026.