No RTI Access to Spouse’s Income Tax Records, Rules High Court

The  High Court’s ruling in the Kapil Agarwal case establishes a vital boundary between the Right to Information and personal privacy within matrimonial disputes. By quashing a CIC order for the disclosure of nearly twenty years of income tax returns, the court reaffirmed that tax filings are “personal information” protected under Section 8(1)(j) of the RTI Act. While acknowledging a spouse’s right to seek maintenance, the judges ruled that the RTI Act cannot be used as a shortcut to bypass standard discovery procedures in family courts.

The decision emphasises that sensitive financial data should remain confidential unless a significant “public interest” is demonstrated. By characterising the dispute as purely private, the court signalled that transparency laws should not be leveraged for personal litigation. Ultimately, this judgment reinforces the sanctity of the taxpayer-state relationship, ensuring that privacy rights are not discarded even in the pursuit of establishing financial capacity for maintenance claims.

Central Issue: Whether income tax details of an individual can be disclosed under the RTI Act to a spouse in matrimonial proceedings on the ground of “larger public interest”?

HC’s Ruling: The High Court allowed the petition and set aside the CIC’s order. The High Court’s ruling in the Kapil Agarwal case reaffirms that income tax returns are “personal information” protected under Section 8(1)(j) of the RTI Act, shielding them from disclosure in matrimonial disputes. By quashing a CIC order that favoured a wife’s request for her husband’s financial data, the court established that the RTI Act is designed for public authority transparency, not for settling private maintenance claims. The bench emphasised that such disclosures lack the “larger public interest” necessary to override individual privacy rights.

Crucially, the court noted that the RTI route is procedurally unnecessary because matrimonial law already contains built-in mechanisms for financial transparency. Following precedents like Rajnesh v. Neha, spouses are already required to submit detailed affidavits of assets and liabilities directly to the family court. This ensures that while a spouse’s right to maintenance is supported by financial clarity, it is achieved through proper judicial channels rather than public records requests, thereby preserving the fundamental right to privacy even during litigation.

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