Differences

This shows you the differences between two versions of the page.


cases:state-of-up-v-raj-narain-1975-sc [2026/08/26 22:45] (current) – created - external edit 127.0.0.1
Line 1: Line 1:
 +{{htmlmetatags>metatag-keywords=(State of U.P. v. Raj Narain,Supreme Court of India RTI,right to know,Article 19(1)(a),foundational,pre-RTI)&metatag-description=(The 1975 Blue Book case: Justice Mathew held the people have a right to know every public act — state privilege is no master key. The seed of the RTI Act.)}}
 +
 +====== State of U.P. v. Raj Narain (1975) — the right-to-know seed ======
 +
 +
 +{{ :social:auto:cases-state-of-up-v-raj-narain-1975-sc.png?direct&1200 |State of U.P. v. Raj Narain — RTI Wiki Citizen Guide 2026 — RTI Wiki}}
 +
 +<WRAP center round info 95%>
 +**Quick Reply:** Raj Narain had beaten Indira Gandhi in the Allahabad High Court's election petition; the State appealed claiming privilege over the **Blue Book** (the Prime Minister's tour-security protocol). The Constitution Bench — **Mathew J.** speaking — held the **privilege for "affairs of state" is not a master key**: the court, not the government, decides what stays secret, and the **people have a right to know every public act** under Article 19(1)(a). Thirty years before the RTI Act, this is its constitutional seed.
 +</WRAP>
 +
 +<WRAP center round info 95%>
 +**Supreme Court of India** · 1975-01-24 · (1975) 4 SCC 428 · **★ Landmark**
 +</WRAP>
 +
 +//The case that said the governed may see what the government does — three decades before Parliament agreed.//
 +
 +===== Case details =====
 +
 +^ Court | Supreme Court of India |
 +^ Decided | 1975-01-24 |
 +^ Citation | (1975) 4 SCC 428 |
 +^ Bench | A.N. Ray, K.K. Mathew, M. Hameedullah Beg, Y.V. Chandrachud, P.N. Bhagwati |
 +^ Petitioner | State of U.P. |
 +^ Respondent | Raj Narain & Ors. |
 +^ RTI Act sections | — |
 +^ Outcome | Applicant allowed |
 +
 +===== Outcome =====
 +
 +Foundational articulation of citizen's right to know the workings of government under Article 19(1)(a).
 +
 +===== The setting =====
 +
 +  * 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?
 +
 +===== What the Court held =====
 +
 +  * **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.
 +
 +===== The line from 1975 to 2005 =====
 +
 +  * **S.P. Gupta v. Union of India** ([[/cases/sp-gupta-v-uoi-1981-sc|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.
 +
 +===== Ratio decidendi =====
 +
 +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).
 +
 +===== Keywords =====
 +
 +right to know, Article 19(1)(a), foundational, pre-RTI
 +
 +===== Later rulings that cite this case =====
 +
 +  * [[/important-decisions/cbse-and-anr-vs-aditya-bandopadhyay|CBSE v. Aditya Bandopadhyay]] (SC 2011)
 +  * [[/important-decisions/electoral-bonds-adr-2024|ADR v. Union of India (Electoral Bonds)]] (SC 2024)
 +
 +===== 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.//
 +
 +  * [[/cases/union-of-india-v-association-for-democratic-reforms-2002-sc|Union of India v. ADR (2002)]] (SC 2002)
 +  * [[/cases/sp-gupta-v-uoi-1981-sc|S.P. Gupta v. Union of India (Judges' Transfer)]] (SC 1981)
 +  * [[/important-decisions/electoral-bonds-adr-2024|ADR v. Union of India (Electoral Bonds)]] (SC 2024)
 +  * [[/important-decisions/k-s-puttaswamy-vs-union-of-india|K.S. Puttaswamy v. Union of India]] (SC 2017)
 +  * [[/cases/sc-rti-educational-right-to-know-2023|Education right-to-know — SC directive]] (SC 2023)
 +
 +===== Related =====
 +
 +  * [[https://righttoinformation.wiki/cases/search?court=SC|All Supreme Court of India rulings in the corpus]]
 +  * [[https://righttoinformation.wiki/cases/search?landmark=1|All landmark rulings]]
 +  * [[:cases:search|Full case-law search]]
 +  * [[:cases|Case-Law Database — overview]]
 +  * [[:pio-rti-reply-guide|PIO RTI Reply Guide]]
 +  * [[:act|The RTI Act, 2005 — annotated]]
 +  * [[https://indiankanoon.org/doc/438670/|External reported text →]]
 +  * [[/book|The RTI Playbook book]]
 +
 +===== FAQs =====
 +==== Is a 1975 Evidence Act ruling still good law for RTI? ====
 +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.
 +==== What was the Blue Book? ====
 +The security protocol for the Prime Minister's travel and tour arrangements — the record the State claimed privilege over in the election dispute.
 +==== Who won the appeal? ====
 +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).
 +==== How do I use it in an RTI matter? ====
 +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.
 +
 +<WRAP center round alert 95%>
 +**Editorial summary, not a certified report.** The ratio here is an editorial compression. Before citing this ruling in a PIO order, FAA speaking order, or any appellate filing, **verify against the full reported decision**. RTI Wiki is not a legal service.
 +</WRAP>
 +
 +
 +
 +//Editorial summary · expanded 27 August 2026; citation, date and Mathew J. holding verified against indiankanoon.org/doc/438670.//
 +
 +{{tag>case-law court-sc landmark}}