State of U.P. v. Raj Narain (1975) — the right-to-know seed

The case that said the governed may see what the government does — three decades before Parliament agreed.

Foundational articulation of citizen's right to know the workings of government under Article 19(1)(a).

• The 1971 Rae Bareli election: Raj Narain lost to Indira Gandhi, then petitioned the Allahabad High Court alleging corrupt practice — and won there in 1975.
• The State appealed to the Supreme Court and claimed privilege under Sections 123 and 162 of the Indian Evidence Act, 1872 over the Blue Book — the security protocol for the Prime Minister's travels — and related documents.
• The question was old and raw: can the executive certify documents secret and end the inquiry?

• The privilege is not a master key. A claim under §123 Evidence Act is addressed to the court, which weighs disclosure against public injury — the government's affidavit is a starting point, not a verdict.
• Mathew J., for the Bench: “the people of this country have a right to know every public act, everything that is done in a public way, by their public functionaries”; the right flows from Article 19(1)(a) — the first articulation of a constitutional right to know.
• Responsible government presupposes an informed people — secrecy over routine public business is not in the public interest.
• The Blue Book itself: routine security arrangements could not be wholesale privileged; the court examined the documents.

• S.P. Gupta v. Union of India (1981) carried the principle to judicial appointments and correspondence.
• The movement years — MKSS's Jan Sunwais, the 1996 Beawar dharna — turned the principle into a demand for a statute.
• The RTI Act, 2005 operationalised it: what Mathew J. located in Article 19(1)(a) became §3's enforceable right, with §§10 and 11 answering the balance Raj Narain struck between openness and injury.

The privilege of non-disclosure for “affairs of state” is claimed before and decided by the court, not the executive; in a responsible democracy the right to know every public act flows from Article 19(1)(a).

right to know, Article 19(1)(a), foundational, pre-RTI

• CBSE v. Aditya Bandopadhyay (SC 2011)
• ADR v. Union of India (Electoral Bonds) (SC 2024)

• Union of India v. ADR (2002) (SC 2002)
• S.P. Gupta v. Union of India (Judges' Transfer) (SC 1981)
• ADR v. Union of India (Electoral Bonds) (SC 2024)
• K.S. Puttaswamy v. Union of India (SC 2017)
• Education right-to-know — SC directive (SC 2023)

• All Supreme Court of India rulings in the corpus
• All landmark rulings
• Full case-law search
• Case-Law Database — overview
• PIO RTI Reply Guide
• The RTI Act, 2005 — annotated
• External reported text →
• The RTI Playbook book

The RTI Act now governs access to records in public authorities, and §22 gives it overriding effect; Raj Narain's constitutional core (right to know under Article 19(1)(a)) is cited to this day — including in the 2024 electoral-bonds judgment.

The security protocol for the Prime Minister's travel and tour arrangements — the record the State claimed privilege over in the election dispute.

The Court examined the documents with the privilege claim failing in material part; the greater legacy is the right-to-know holding, not the election result (the Emergency had already overtaken the case politically).

Cite it for the proposition that secrecy claims are tested, not obeyed — the ancestor of demanding a reasoned §8 refusal, and of the Commission's power to examine records itself.

Editorial summary · expanded 27 August 2026; citation, date and Mathew J. holding verified against indiankanoon.org/doc/438670.