cases:dav-college-trust-v-director-2019-sc
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D.A.V. College Trust and Management Society v. Director of Public Instructions

Supreme Court of India · 2019-09-17 · (2019) 9 SCC 185 · ★ Landmark

Non-govt colleges receiving substantial State financing fall within §2(h); must appoint PIOs.

Case details

Court Supreme Court of India
Decided 2019-09-17
Citation (2019) 9 SCC 185
Bench L. Nageswara Rao, Deepak Gupta
Petitioner D.A.V. College Trust
Respondent Director of Public Instructions (Colleges) & Ors.
RTI Act sections §2(h)
Outcome Rejected

Outcome

Non-government educational trusts receiving substantial government aid are 'public authorities' under §2(h).

Ratio decidendi

Educational institutions, including non-government colleges, that receive substantial government aid — measured against their overall operating budget — are 'public authorities' under §2(h) and must comply with the RTI Act.

Keywords

§2(h), educational institutions, substantial financing, DAV

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Editorial summary · last reviewed 21 April 2026.

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