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+{{htmlmetatags>metatag-keywords=(RTI relevance test,Adesh Kumar v Union of India,Section 3 RTI right to information,information cannot be denied as irrelevant,Delhi HC RTI 2014)
+metatag-description=(Delhi HC 2014 ruling: a PIO cannot deny RTI by saying the information is irrelevant. Section 3 gives citizens an unconditional right to information held by.)}}
+====== RTI cannot be denied as "irrelevant" — Adesh Kumar v. Union of India ======
+**The Delhi High Court ruled in 2014 that a Public Information Officer cannot deny an RTI application by labelling the requested information as "irrelevant" or "unnecessary". Section 3 of the Right to Information Act, 2005 gives every citizen an unconditional right to information held by a public authority — the citizen does not have to justify why the information is needed.**
+**Adesh Kumar v. Union of India and Others**
+{{tag>delhi-hc section-3 rti-right-to-information relevance-test pio-refusal 2014}}{{like>}}
+===== The issue before the Court =====
+The petitioner had filed an RTI under §6 of the Right to Information Act, 2005. The PIO refused, observing that the information sought was **"not relevant"** and **"not germane"** to any public interest. The CIC had upheld the refusal. The applicant approached the Delhi High Court.
+The threshold question: **can a PIO refuse an RTI on the ground that the information sought is not relevant or not necessary?**
+===== The holding =====
+The Delhi High Court (single judge bench) emphatically said **NO**. The key passage:
+> "**The question whether the information sought by the petitioner is relevant or necessary is not relevant or germane in the context of the Act; a citizen has a right to information by virtue of Section 3 of the Act and the same is not conditional on the information being relevant.**" — paragraph 18.
+In other words, **§3 of the RTI Act creates an unconditional right**. The PIO's only legitimate grounds for refusal are the **enumerated exemptions in §8 and §9** of the RTI Act — and "irrelevance" is not on that list.
+===== Why this case matters for citizens =====
+This is one of the **most-cited Delhi HC rulings** in routine RTI matters because:
+  - **Many PIOs first try to refuse** by saying "your application is vague" or "this information is not relevant to you" or "you have not stated the purpose". These are **NOT valid grounds** under the RTI Act.
+  - **Section 6(2) of the RTI Act expressly forbids** the PIO from asking for the **reason for seeking information** (except contact details).
+  - **Adesh Kumar** is the case you cite when the PIO tries the "irrelevance" gambit.
+===== The PIO refusal-grounds checklist =====
+A PIO can ONLY refuse RTI on these grounds:
+  - **§8(1)(a)** — sovereignty / integrity / security
+  - **§8(1)(b)** — expressly forbidden by court
+  - **§8(1)(c)** — breach of privilege of Parliament / Legislature
+  - **§8(1)(d)** — commercial confidence / trade secret / IP
+  - **§8(1)(e)** — fiduciary relationship
+  - **§8(1)(f)** — foreign government info in confidence
+  - **§8(1)(g)** — would endanger life / source / process
+  - **§8(1)(h)** — impeded process of investigation / prosecution
+  - **§8(1)(i)** — Cabinet papers (with carve-out post-decision)
+  - **§8(1)(j)** — personal information (proviso amended by DPDP 2023)
+  - **§9** — third-party copyright
+**Anything outside this list — including "irrelevance" — is an unlawful refusal.**
+===== Status as of May 2026 =====
+The ruling remains good law and is routinely cited at FAAs and Information Commissions. The **Digital Personal Data Protection Act, 2023** (in force 14 November 2025) does not affect this case — the §44(3) amendment touched only §8(1)(j); §3 (the right itself) is intact.
+===== How to use this ruling in your RTI =====
+If your RTI is rejected with language like "*the information sought is irrelevant*" or "*you have not stated why you need this*", file a §19(1) First Appeal within 30 days, citing:
+  - **Section 3 of the RTI Act, 2005** — the unconditional right.
+  - **Section 6(2) of the RTI Act, 2005** — the express bar on asking the applicant to state reasons.
+  - **Adesh Kumar v. Union of India**, Delhi High Court, WP (C) 3543/2014, decided 16 December 2014 — the irrelevance-is-not-a-ground rule.
+Use our [[https://righttoinformation.wiki/tools/first-appeal-app.html|First Appeal Builder]] — it has this citation pre-loaded.
+===== Sections engaged =====
+  * **Section 3** — Right to information; "Subject to the provisions of this Act, all citizens shall have the right to information."
+  * **Section 6(2)** — Bar on asking for reasons; "An applicant making request for information shall not be required to give any reason for requesting the information."
+  * **Section 8** — The exemption list (closed list).
+  * **Section 19(1)** — First Appeal.
+===== Citation =====
+**Adesh Kumar v. Union of India and Others**, **W.P. (C) 3543/2014**, decided **16 December 2014** by the Delhi High Court (single bench). The full judgment PDF is in the case-law media folder.
+===== Sources =====
+  * Delhi High Court, **Adesh Kumar v. Union of India**, 16 December 2014. Cited routinely at CIC and SIC.
+  * **Right to Information Act, 2005**, §3, §6(2), §8, §19. [[:act|Full text]].
+  * **Bhagat Singh v. Chief Information Commissioner** — Delhi HC 2008 — companion ruling that procedural objections cannot defeat RTI.
+===== Related on RTI Wiki =====
+  * [[:important-decisions:court:bhagat-singh-vs-cic|Bhagat Singh v. CIC — procedural-objections-cannot-defeat-RTI]]
+  * [[:important-decisions:court:girish-ramchandra-deshpande|Girish Deshpande — §8(1)(j) personal-information test]]
+  * [[:important-decisions:court:anjali-bhardwaj-vs-union-of-india|Anjali Bhardwaj v. UoI — IC vacancies + transparency]]
+  * [[https://righttoinformation.wiki/tools/first-appeal-app.html|First Appeal Builder]]
+  * [[:cases|RTI case-law database]]
+  * [[:act|RTI Act, 2005]]
+//Last reviewed on: 4 May 2026 — RTI Wiki editorial team.//
+{{tag>delhi-hc adesh-kumar relevance-test section-3 section-6-2 pio-refusal 2014 2026-update}}