Table of Contents
Service Records RTIs — A PIO Playbook
Scope. This playbook covers RTIs seeking service records of a named government officer or employee — pay drawn, APAR/ACR grading, leave records, disciplinary proceedings, transfers, promotions, vigilance clearance. Governed by Section 8(1)(j) as interpreted in Girish Deshpande.
Legal framework
- 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.
Decision matrix — what's disclosable
| = Data element | = Default | = Reasoning |
| Name, designation, posting | Disclose | Section 4(1)(b)(ix) proactive |
| Pay scale + allowance structure | Disclose | Public pay scales are notified |
| Actual salary drawn (month-by-month) | Partial | Structure disclosable; bank/PAN redacted under §10 |
| APAR / ACR grading | Exempt | Deshpande |
| Medical leave details | Exempt | Deshpande + medical confidentiality |
| Casual leave aggregate (per year) | Borderline | Balanced under §8(2) |
| Disciplinary — final order | Disclose | Post-decisional |
| Disciplinary — pre-decisional | Exempt | Pre-decisional + §8(1)(j) |
| Vigilance clearance | Exempt | Deshpande |
| Transfer / posting orders | Mostly disclose | Institutional records |
| Promotion — DPC minutes | Exempt | Internal deliberation |
| Promotion — final order | Disclose | Post-decisional |
Decision framework
- Step 1. Is the RTI about the applicant's own service record? If yes, disclose (Aditya Bandopadhyay self-data principle).
- Step 2. If third-party, classify the request per the matrix above.
- Step 3. Issue Section 11 notice to the officer concerned — always applicable here.
- Step 4. Consider public-interest override under §8(2). Genuine cases: vigilance petitioner, documented impropriety, misuse-of-position claim, public-servant-conduct concern.
- Step 5. Apply §10 severability — redact PAN, Aadhaar, bank, phone, home address even in disclosable elements.
- Step 6. Draft speaking reply with Deshpande citation if declining.
Template — service-record denial under §8(1)(j)
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].
Subject-wise examples
- 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.
Case law
- 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.
Common mistakes
- 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).
Pro tips
- 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.
FAQs
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.
Conclusion
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.
Related reading
Sources
- RTI Act, 2005, Sections 8(1)(j), 8(2), 10, 11
- Girish Deshpande, (2013) 1 SCC 212
Last reviewed: 21 April 2026.


Discussion