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R.K. Jain v. Union of India
R.K. Jain v. Union of India (Supreme Court of India, 2013-04-16) (2013) 14 SCC 794 is a ruling on the Right to Information Act, 2005 — Sections 8(1)(i), 10. File noting is not Cabinet papers; post-decisional disclosure mandatory. Section 8(1)(i) exemption is limited to Cabinet-level deliberations of the Council of Ministers, Secretaries and other officers.
Holding
File noting is not Cabinet papers; post-decisional disclosure mandatory.
Ratio
Section 8(1)(i) exemption is limited to Cabinet-level deliberations of the Council of Ministers, Secretaries and other officers. Routine departmental file noting at Section Officer / Under Secretary level is administrative record and disclosable. The proviso to §8(1)(i) mandates post-decisional disclosure.
Section(s) applied
- Section 8(1)(i)
- Section 10
Practitioner takeaway
§8(1)(i) protects only Cabinet-level deliberation; routine file noting disclosable.
Citation
- Citation: (2013) 14 SCC 794
- Court: Supreme Court of India
- Date: 2013-04-16
- Outcome: allowed
- Reporter / Cause-list: (2013) 14 SCC 794
Related
Last reviewed: 23 April 2026.

Discussion