Facts of the Case:

Petitioner-husband and respondent-wife were engaged in a matrimonial dispute. Respondent-wife filed a maintenance claim, after which the petitioner sought information under the Right to Information Act, 2005 (RTI) from the Income-tax Department. The Central Information Commission (CIC) directed the disclosure of the petitioner’s net taxable income for the financial year 2007-08 onwards. The petitioner approached the Delhi High Court seeking to set aside the CIC’s order, preventing disclosure of his income details to the respondent-wife.

Issues Involved:

Whether information related to an individual’s income-tax matters, particularly that of a third party, can be disclosed under the RTI Act, 2005, especially in the context of maintenance proceedings.

Petitioner’s Arguments:

  • The petitioner contended that income-tax details constitute personal information and their disclosure would amount to unwarranted invasion of privacy.
  • Disclosure under RTI cannot be justified as there is no larger public interest involved.
  • Adequate remedies exist under law via mandatory financial affidavits filed in maintenance proceedings.

Respondent’s Arguments:

  • Respondent-wife argued that disclosure of the petitioner’s income details was necessary for proper adjudication of her maintenance claim.
  • She relied on the CIC’s direction to obtain information regarding the petitioner’s taxable income for the relevant years.

Court Findings / Decision:

  • Section 8(1)(j) of the RTI Act protects personal information from disclosure unless larger public interest is established.
  • Income-tax information of an individual constitutes personal information and is ordinarily exempted from disclosure.
  • Reliance on Girish Ramchandra Deshpande v. Central Information Commissioner (2013) 351 ITR 472 confirmed that income-tax returns fall under personal information exempt under Section 8(1)(j).
  • Disclosure for adjudicating a maintenance claim is unnecessary as parties are required to submit income, assets, and liability affidavits per Rajnesh v. Neha (2020) 2 SCC 324.
  • The CIC’s directions were unsustainable in law; the impugned order was set aside.
  • Parties may avail remedies under existing law by filing financial affidavits mandated in maintenance proceedings.

Important Clarifications:

  • RTI cannot be used as a tool to bypass legal procedures for obtaining financial information in personal disputes.
  • Personal information, including income-tax returns, remains confidential unless disclosure serves a larger public interest.
  • Financial affidavits in maintenance cases provide an adequate and lawful mechanism to access necessary financial details of a spouse.

Relevant Section:

  • Section 8(1)(j), RTI Act, 2005 – Protection of personal information unless larger public interest is involved

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