PM Modi Degree Case: The Delhi High Court on Monday ruled that Delhi University is not required to disclose details of Prime Minister Narendra Modi’s graduation degree, setting aside the Central Information Commissioner’s (CIC) order directing its release.
Justice Sachin Datta, delivering the order, said, “The fact that the information sought pertains to a public figure does not extinguish privacy/confidentiality rights over personal data, unconnected with public duties.”
The court noted that academic records constitute personal information, even for individuals holding public office, and there was no overriding public interest in disclosing them. It further clarified that such information would only be relevant if a specific educational qualification were a statutory requirement for holding a particular public post.
“However, in the present case, no public interest is implicit in the disclosure of the information sought through the RTI application. The concerned educational qualifications are not in the nature of any statutory requirement for holding public office or discharging official responsibilities,” the order stated.
University’s Argument on Privacy and Fiduciary Responsibility
The case originated in 2016 when the CIC allowed inspection of records of all students who cleared the BA exam in 1978, the year Prime Minister Modi is said to have graduated. Delhi University challenged the order, which was stayed in January 2017.
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During the hearing, Solicitor General Tushar Mehta, representing Delhi University, argued that the CIC’s order should be quashed since the “right to privacy” outweighed the “right to know.” The university submitted that it holds students’ records in a fiduciary capacity and that “mere curiosity,” in the absence of public interest, did not justify disclosure under the RTI Act.
The court observed that university statutes only permitted the issuance of official mark sheets and transcripts directly to the student concerned and not to third parties. While Delhi University told the court it was willing to present Prime Minister Modi’s degree records before the court, it said the information could not be disclosed to “strangers” under RTI.
Senior Advocate Sanjay Hegde, appearing for RTI applicant Neeraj Sharma, defended the CIC’s order, contending that the Right to Information Act permitted disclosure in the larger public interest. He added that such information was traditionally displayed on university notice boards, websites, and even in newspapers.
Justice Datta ultimately allowed the appeal by Delhi University, setting aside the CIC’s directive.
