Delhi High Court to Hear on Wednesday Appeals Related to Disclosure of PM Modi’s Degree

The Delhi High Court is set to hear on Wednesday four appeals seeking the disclosure of Prime Minister Narendra Modi’s educational records.

A Division Bench comprising Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela will take up the appeals filed by RTI applicant Neeraj, AAP leader Sanjay Singh, and advocate Mohd Irshad.

These appeals challenge a single-judge order that had overturned a Central Information Commission (CIC) directive requiring the disclosure of the Prime Minister’s degree details.

While setting aside the CIC orders directing disclosure of PM Modi’s university degree, the single judge had clarified that the Right to Information Act, 2005, was enacted to promote transparency and accountability in governance, not to serve as “fodder for sensationalism.”

Delivering a stern reminder on the spirit of the law, the Court cautioned against its misuse for personal vendettas or publicity-driven motives.

Justice Sachin Datta, in University of Delhi v. Neeraj & Anr., held that marksheets, results, degree certificates, and other academic records, even of public officials, constitute personal information protected under Section 8(1)(j) of the RTI Act.

“The CIC misdirected itself in relying upon anecdotal material and subjective assessments,” the Court observed. “Whether or not Delhi University has previously published certain results online cannot determine the interpretation of Section 8(1)(j).”

The High Court found that the CIC’s directions to disclose PM Modi’s degree from Delhi University and Smriti Irani’s Class X and XII records from the CBSE were legally unsustainable. Both institutions had argued that they hold academic records in a fiduciary capacity and owe a duty of confidentiality to their students, a position the Court accepted.

“The University is obligated to issue results exclusively through official mark sheets and transcripts to the concerned student,” Justice Datta said. “The framework does not permit disclosure of marks or grades to any third party. There is an implicit duty of trust and confidentiality in handling students’ academic records.”

RTI applicant Neeraj Kumar had sought records of students who appeared for Delhi University’s BA examination in 1978, including names, roll numbers, and marks. The University refused, citing third-party privacy.

Neeraj challenged this before the CIC, which directed Delhi University to allow inspection of records, observing that the information was part of the University’s register, a public document. The University then appealed before the High Court.

Allowing DU’s appeal, the single judge emphasised that disclosure of educational records is justified only when a qualification is a statutory requirement for holding a particular office. Otherwise, the public interest threshold under the RTI Act is not met.

The Court also warned against misuse of RTI requests: “What may superficially appear to be an innocuous disclosure could open the floodgates of indiscriminate demands, motivated by curiosity or sensationalism rather than genuine public interest.”

In its 175-page judgment, the Bench further clarified that Section 8(3) of the RTI Act does not override the privacy exemption under Section 8(1)(j). Information of a personal nature remains protected unless a demonstrable and compelling public interest outweighs the right to privacy.

Case Title: Mohd Irshad v. DU & other connected matters

Bench: Chief Justice Devendra Kumar Upadhyaya and Justice Tushar Rao Gedela

Expected Hearing: 12 November 2025