Part of the PIO / FAA knowledge base. See also how to cite case law.

The Bombay HC hears the largest RTI-related caseload from Maharashtra and Goa, including high-volume appeals from the Maharashtra SIC (among India's busiest). Its rulings on Thalappalam-type co-operatives, privacy of bank customers, and educational trust disclosures have influenced the Supreme Court and other High Courts.

• Ratio. Medical records of a prisoner accessed by a third party are subject to §8(1)(j); however, if the public authority itself is the custodian and no larger public interest is shown, the denial stands.
• PIO takeaway. Third-party medical data = presumptive denial, unless larger public interest is articulated.

• Ratio. “Public interest” under §8(2) is not mere curiosity; the overriding standard must be demonstrable.
• PIO takeaway. When applying §8(2), record the specific public interest — mere “interest of the applicant” is insufficient.

• Ratio. Substantial financing of an NGO by the State brings it within §2(h)(d)(ii) as a public authority.
• PIO takeaway. NGOs receiving ≥ threshold of state funding are in scope; jurisdiction is tested on substantive control, not merely formal ownership.

• Ratio. The CIC cannot re-adjudicate Section 8 denials mechanically; the “harm test” must be applied with recorded reasoning.
• PIO takeaway. Denials must be reasoned; mechanical invocation of §8(1) ground fails at FAA / CIC / HC.

• Ratio. Co-operative banks registered under Maharashtra Co-op Societies Act are not automatically public authorities — Thalappalam test applies state-specific.
• PIO takeaway. For co-operative banks, the substantial-financing test, not registration itself, determines RTI scope.

• Ratio. Bombay HC in multiple orders has applied Shaunak Satya to protect examiner-identity and model-answer data for CA, CS, CMA, and insurance-regulator exams.
• PIO takeaway. Model-answers and examiner IP are protected; scored marks remain disclosable.

• Ratio. Public-sector undertakings (PSUs) cannot claim immunity from RTI solely on the “commercial” or “proprietary” ground without applying the harm test.
• PIO takeaway. For a PSU PIO, §8(1)(d) requires specific trade-secret or competitive-harm reasoning.

• Ratio. Trade-union registration and recognition records are public; internal elections and office-bearer rosters are disclosable to members.
• PIO takeaway. Registrar of Trade Unions is a public authority; member-level rights apply.

• Ratio. Section 8(1)(j) bars disclosure of confidential personal data but does not protect data whose disclosure has been normalised (PAN-less returns, published lists).
• PIO takeaway. The §8(1)(j) ground fails where the same information is already in the public domain.

• Ratio. Even religious organisations receiving substantial grant or holding beneficial public interest may be tested as public authorities under §2(h).
• PIO takeaway. Beneficiary-of-public-funds test is live for faith-based bodies too; the decision rests on factual control / financing.

Use these one-liners in your reply / appeal:

1. “The Bombay High Court in Public Concern for Governance Trust held that substantial state financing brings an NGO within §2(h)(d)(ii).”
2. “In Shailesh Gandhi, the Bombay High Court held that §8(1) denials must be reasoned with a specific harm test; mechanical citation fails.”
3. “In CIDCO, the Bombay High Court held that a PSU cannot claim §8(1)(d) without demonstrating specific competitive harm.”

• Pick the rule, not the case-name flourish. The FAA responds to ratio, not to volume of citations.
• Attach the first page of the judgement — PDFs from the HC website or India Kanoon are acceptable.
• Combine with Supreme Court anchor. Pair Shaunak Satya (SC) with the Bombay HC application; CIC and SIC like seeing both.

• Treating Public Concern for Governance Trust as an open door — it hinges on the financing threshold.
• Over-citing Shailesh Gandhi — it is about procedure (reasoned denial), not the merit of a specific exemption.
• Missing state-specific rules — Maharashtra RTI Rules have fee and procedural variations.

• PIO / FAA knowledge base
• How to cite case law in PIO replies
• Supreme Court RTI rulings (pending)
• Madras HC rulings
• Kerala HC rulings

• Bombay High Court judgements (India Kanoon / official HC portal)
• Maharashtra State Information Commission annual reports
• RTI Act, 2005

Last reviewed: 21 April 2026.