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

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 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.

This is one of the most-cited Delhi HC rulings in routine RTI matters because:

1. 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.
2. Section 6(2) of the RTI Act expressly forbids the PIO from asking for the reason for seeking information (except contact details).
3. Adesh Kumar is the case you cite when the PIO tries the “irrelevance” gambit.

A PIO can ONLY refuse RTI on these grounds:

1. §8(1)(a) — sovereignty / integrity / security
2. §8(1)(b) — expressly forbidden by court
3. §8(1)© — breach of privilege of Parliament / Legislature
4. §8(1)(d) — commercial confidence / trade secret / IP
5. §8(1)(e) — fiduciary relationship
6. §8(1)(f) — foreign government info in confidence
7. §8(1)(g) — would endanger life / source / process
8. §8(1)(h) — impeded process of investigation / prosecution
9. §8(1)(i) — Cabinet papers (with carve-out post-decision)
10. §8(1)(j) — personal information (proviso amended by DPDP 2023)
11. §9 — third-party copyright

Anything outside this list — including “irrelevance” — is an unlawful refusal.

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.

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:

1. Section 3 of the RTI Act, 2005 — the unconditional right.
2. Section 6(2) of the RTI Act, 2005 — the express bar on asking the applicant to state reasons.
3. 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 First Appeal Builder — it has this citation pre-loaded.

• 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.

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.

• 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. Full text.
• Bhagat Singh v. Chief Information Commissioner — Delhi HC 2008 — companion ruling that procedural objections cannot defeat RTI.

• Bhagat Singh v. CIC — procedural-objections-cannot-defeat-RTI
• Girish Deshpande — §8(1)(j) personal-information test
• Anjali Bhardwaj v. UoI — IC vacancies + transparency
• First Appeal Builder
• RTI case-law database
• RTI Act, 2005

Last reviewed on: 4 May 2026 — RTI Wiki editorial team.