A private company is generally not a public authority under §2(h). But three categories complicate that: substantially financed, performing public function, and PPP arrangements.

Thalappalam Service Coop Bank v. State of Kerala (2013) — “substantial finance” requires more than mere government contribution. Direct grants/subsidies must be a major funding source.

• BCCI — held public function via *BCCI v. Cricket Assoc of Bihar (2015)*; some High Courts have applied RTI; SC has not finally ruled.
• IOA — Delhi HC (2014) held subject to RTI.
• MTNL/LIC/PSUs — clearly public; some private listed entities (HDFC, Reliance) are not.

PPP entities operating concessions on public land/assets — under increasing pressure to disclose. Several CIC orders direct that PPP-built airports, highways, metros must disclose project-specific information.

• Real-estate developers in PMAY projects — disclosure of beneficiary lists ordered.
• Educational PPPs — RTI applies for scheme-related data.
• Healthcare PPPs under Ayushman — ordered to disclose scheme-financial data.

1. File to the government counterpart of the PPP first; they are the conduit.
2. Cite Thalappalam + Cricket Assoc of Bihar + Manohar Parrikar (Bom HC 2010) as conceptual ladder.
3. Frame ask in terms of scheme-implementation data, not “private business records”.

1. Thalappalam Service Coop Bank v. State of Kerala (2013).
2. BCCI v. Cricket Association of Bihar (2015).
3. CIC orders on PPP transparency.

Last reviewed: 25 April 2026.