Table of Contents

Section 8(1)(e) — Fiduciary Relationship — PIO Framework

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In one line. A fiduciary relationship requires choice + trust + benefit of the provider — lawyer/client, doctor/patient, banker/customer, trustee/beneficiary. Information submitted to a public authority under a statutory requirement, employee service records held by the employer, and exam-answer-scripts are not fiduciary.

Statutory text

Information available to a person in his fiduciary relationship, unless the competent authority is satisfied that the larger public interest warrants the disclosure.

What it means in practice

A fiduciary relationship requires choice + trust + benefit of the provider — lawyer/client, doctor/patient, banker/customer, trustee/beneficiary. Information submitted to a public authority under a statutory requirement, employee service records held by the employer, and exam-answer-scripts are not fiduciary.

Case law

PIO takeaway

Record why the specific record qualifies as fiduciary. Statutory compliance, employment, or regulation alone do not meet the test.

Quick Answer: §8(1)(e) Fiduciary

When Is §8(1)(e) Valid?

Request Fiduciary? Outcome
Examination answer-scripts and own marks No Disclose — Aditya Bandopadhyay (SC 2011)
Examiner's moderation working notes Yes Protected — Shaunak Satya (SC 2011)
RBI regulatory inspection reports of banks No Disclose — Jayantilal Mistry (SC 2015)
Individual bank customer account details Yes Protected — fiduciary bank-customer (qualified by HDFC v. CIC 2020)
Employee service records held by employer No Not fiduciary — Deshpande and progeny
Insurance claim file (insurer is public authority) Yes Fiduciary insurer-insured
Cabinet confidentiality / collegium documents No §8(1)(i), not §8(1)(e)
Information submitted under a statute by compulsion No Not fiduciary — absence of “choice”

PIO Decision Framework — §8(1)(e)

  1. Is the provider's submission voluntary or compelled by law? Compelled = not fiduciary.
  2. Was the information given for the provider's own benefit? If not, not fiduciary.
  3. Was there choice of confidant? Statutory monopoly provider means no choice.
  4. Does the holder owe a higher duty of care? Lawyer / doctor / trustee — yes.
  5. Is there §8(2) public interest override? Record reasoning either way.

Landmark case law

FAQs

Q1. Are an employee's own service records fiduciary?

No. Service records are held by the employer in an employer-employee relationship, not in fiduciary capacity. An employee can access their own record directly under §2(f).

Q2. Are bank inspection reports fiduciary?

No. The Supreme Court in Jayantilal Mistry held that the RBI and a commercial bank are in a regulator-regulated relationship, which is not fiduciary.

Q3. What about an examiner's scoring?

The examiner-examinee relationship is not fiduciary (Aditya Bandopadhyay). But internal moderation working notes are fiduciary (Shaunak Satya).

Q4. Does public interest override §8(1)(e)?

Yes. §8(2) permits disclosure if public interest in disclosure outweighs the harm to the protected relationship. The PIO must record this balancing in writing.

Q5. Is the lawyer-client privilege fiduciary under §8(1)(e)?

Yes. But legal advice rendered by in-house government counsel in their official capacity, on matters of public policy, can lose privilege post-decision. Case-by-case.

What Should You Do Next?

Deep dive

Sources


Last reviewed: 24 April 2026.