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--- important-decisions:icai-vs-shaunak-h-satya [2023/04/15 11:55] – Shrawan
+++ important-decisions:icai-vs-shaunak-h-satya [2026/04/19 07:40] (current) – external edit 127.0.0.1
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 ====== Supreme Court- ICAI Vs Shaunak H.Satya ======
-{{like>}}{{tag>Supreme Court}}
+<WRAP center round info 95%>
+**In plain English**
+An unsuccessful candidate in the Chartered Accountancy examination applied to the Institute of Chartered Accountants of India for information relating to the evaluation process. The Institute declined, invoking Section 8(1)(e) of the Right to Information Act on the ground that the records were held in a fiduciary capacity.
+The Supreme Court held that an examining body does not stand in a fiduciary relationship with its examiners, moderators, or candidates within the sense of Section 8(1)(e). Section 8(1)(e) protects a narrower class of relationships such as lawyer-client, doctor-patient, and trustee-beneficiary. Instructions to examiners and model answers are confidential during the evaluation period. Once evaluation is complete, that character is lost and the records are disclosable. The Institute's standard criteria for moderation are disclosable.
+**What it means for you.** A candidate can obtain instructions to examiners, moderation standards, and similar evaluation records from an examining body once the evaluation round is over. The body cannot rely on a generic "fiduciary" objection.
+**Current status.** The holding on the scope of Section 8(1)(e) remains good law. The 14 November 2025 amendment to Section 8(1)(j) does not affect the holding.
+</WRAP>
+{{tag>supreme court}}
 Reportable IN THE SUPREME COURT OF INDIA \\
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 September 2, 2011. (A K Patnaik)
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+----
+===== Status as of 19 April 2026 =====
+Remains good law on the scope of the fiduciary-relationship exemption under Section 8(1)(e). The examining body's relationship with its examiners, moderators, and candidates is not a fiduciary one. Instructions to examiners constitute confidential information only where disclosure would affect the conduct of examinations, and that protection ends once the evaluation process is over. The amendment to Section 8(1)(j) by Section 44(3) of the Digital Personal Data Protection Act, 2023 does not affect the holding on Section 8(1)(e).
+===== Sections engaged =====
+  * Section 2(f). Definition of "information".
+  * Section 8(1)(d). Commercial confidence.
+  * Section 8(1)(e). Information held in a fiduciary relationship.
+===== Citation =====
+Institute of Chartered Accountants of India v. Shaunak H. Satya and Ors., (2011) 8 SCC 781. Decided on 2 September 2011 by the Supreme Court of India. Bench: R. V. Raveendran and A. K. Patnaik, JJ.
+===== Sources =====
+  - Supreme Court of India, judgment dated 2 September 2011.
+  - The Right to Information Act, 2005, Section 8(1)(d) and (e).
+===== Last reviewed on =====
+April 2026
+{{tag>rti case-law supreme-court section-8-1-e fiduciary-relationship}}

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