Central Information Commission vs. Delhi Development Authority [July 10, 2024]
Citation: 2024 INSC 513; [2024] 6 Supreme 10668
Background and Facts
This Supreme Court case arose from a challenge to the Central Information Commission (Management) Regulations, 2007, framed by the Central Information Commission (CIC) under the Right to Information Act, 2005 (RTI Act). The dispute began when an RTI applicant sought information from the Delhi Development Authority (DDA) regarding modifications to the Delhi Master Plan 2021 and compliance with Section 4 of the RTI Act, which mandates proactive disclosure by public authorities. The CIC, in response, constituted a committee to inquire into DDA’s compliance and framed regulations to manage its internal affairs, including the constitution of benches and delegation of powers.
The DDA challenged these actions before the Delhi High Court, which struck down the CIC’s regulations as ultra vires, holding that the CIC had exceeded its statutory powers and could not constitute benches or delegate inquiry responsibilities to committees. The High Court’s restrictive interpretation of the RTI Act led to an appeal before the Supreme Court.
Key Issues
Whether the CIC has the authority under the RTI Act to frame its own regulations, constitute benches, and delegate its powers to committees.
The scope of the CIC’s powers under Sections 12(4) and 15(4) of the RTI Act.
The autonomy of the CIC in managing its internal affairs and ensuring effective functioning.
Supreme Court’s Analysis and Findings
The Supreme Court, in a bench led by Justices Vikram Nath and Satish Chandra Sharma, reversed the High Court’s judgment, holding that the CIC’s powers of “superintendence, direction, and management” under Sections 12(4) and 15(4) of the RTI Act are broad and inherently empower the CIC to frame its own regulations and delegate responsibilities to committees.
The Court clarified that while the RTI Act does not explicitly state the power to frame regulations or constitute benches, the wide language of Sections 12(4) and 15(4) implies such authority is necessary for the effective and expeditious functioning of the Commission.
The Supreme Court emphasized that the autonomy of the CIC is essential for promoting transparency and accountability, which are the cornerstones of the RTI Act. Any undue interference with its administrative powers would impede its ability to efficiently handle a large volume of cases.
The Court stated:
“The CIC must be allowed to operate independently and exercise its powers of superintendence, direction, and management without external constraints. Allowing the Commission to function autonomously ensures that it can fulfil its role in promoting transparency and accountability... The ability to form benches and allocate work among Information Commissioners is essential for the CIC to manage its workload effectively and uphold the citizens’ right to information.”
Accordingly, the Supreme Court set aside the High Court’s judgment and upheld the validity of the CIC (Management) Regulations, 2007, including the CIC’s power to constitute benches and delegate inquiry responsibilities to committees.
Conclusion and Significance
The Supreme Court’s decision is a landmark affirmation of the CIC’s autonomy and administrative powers under the RTI Act.
The judgment clarifies that the CIC has the authority to frame regulations, constitute benches, and delegate responsibilities, ensuring efficient and effective functioning in promoting citizens’ right to information.
This ruling strengthens the institutional independence of the CIC and provides clarity on the scope of its powers under the RTI framework.
In summary: The Supreme Court upheld the CIC’s power to frame its own regulations and constitute benches, reversing the Delhi High Court’s restrictive interpretation and reinforcing the CIC’s autonomy and central role in the RTI regime.
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