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Co-operative society records under RTI — Gujarat HC 2019
Gujarat High Court · 2019-04-18 · 2019 SCC OnLine Guj 756
Substantial-finance test from Thalappalam applies to Gujarat co-operatives.
Case details
| Court | Gujarat High Court |
|---|---|
| Decided | 2019-04-18 |
| Citation | 2019 SCC OnLine Guj 756 |
| Bench | R, ., M, ., , C, h, h, a, y, a, , J |
| Petitioner | Savli Taluka Co-op. Agri. & Rural Dev. Bank Ltd. |
| Respondent | Gujarat State Information Commission |
| RTI Act sections | §2(h) |
| Outcome | partly allowed |
Outcome
Co-operative societies substantially financed by government are §2(h) public authorities; purely member-run societies are not.
Ratio decidendi
Applying the Supreme Court test in Thalappalam Service Co-op. Bank v. State of Kerala (2013), the Court held that a co-operative society is a §2(h)(d)(i) public authority only where there is substantial government financing or control. Mere registration under the Co-operative Societies Act does not by itself trigger §2(h). Where societies receive continuing budgetary support or their Board is state-nominated, they come within the Act. The petitioner society here did not meet the threshold and was outside §2(h).
Keywords
section 2(h), co-operative society, Thalappalam, substantial financing, Gujarat
Similar cases in the corpus
These rulings have the closest editorial ratio to this case — computed by tf-idf cosine similarity over ratio, keywords and Act sections. Useful starting points if you are researching the same point of law.
- Urban Co-operative Bank records — Karnataka HC 2024 (HC-KAR 2024)
- Cooperative societies — Karnataka HC (HC-KAR 2019)
Related
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Editorial summary · last reviewed 21 April 2026.
Discussion