Part of the PIO / FAA knowledge base. See also Bombay HC and Madras HC rulings.

Kerala HC handed down the ratio that the Supreme Court later affirmed in Thalappalam Service Cooperative Bank Ltd. v. State of Kerala (2013). Its rulings on state information commissions, statutory-body disclosures, and medical-college regulation are foundational.

• Ratio. Co-operative societies registered under the Co-operative Societies Act are not automatically public authorities under §2(h); the substantial-financing test under §2(h)(d)(ii) must be independently satisfied.
• PIO takeaway. For co-operative banks, the “substantial finance / control” test governs; mere registration does not make the body public.

• Ratio. Category-wise cut-offs, scored marks, and rank-data are disclosable; examiner-identity and model answers are protected.
• PIO takeaway. PSC records follow Aditya Bandopadhyay + Shaunak Satya exactly.

• Ratio. File-notings are part of the “record” under §2(i) and are disclosable, subject to §8(1).
• PIO takeaway. File-noting is not automatically exempt; §8(1) grounds must be evaluated line by line.

• Ratio. Medical colleges funded by the State and regulated by the MCI / NMC are public authorities; faculty governance and inspection records are disclosable.
• PIO takeaway. Medical-college inspection and faculty records fall under §2(h); §8(1)(d) needs specific commercial harm.

• Ratio. The SIC cannot sit in substitution over policy decisions; it enforces disclosure but does not direct administrative action.
• PIO takeaway. SIC orders that instruct the PIO to “take action” beyond disclosure are reviewable on jurisdiction.

• Ratio. §8(1)(d) commercial confidence requires a demonstrable competitive harm; financial-bid data redaction is permissible post-award but only for genuinely competitive elements.
• PIO takeaway. For tenders, technical evaluation post-award is disclosable; only narrowly defined commercial data stays redacted.

• Ratio. Life-and-liberty requests under §7(1) proviso must be handled within 48 hours; the PIO cannot use the normal 30-day clock.
• PIO takeaway. Where life/liberty is invoked, treat as urgent; penalty under §20 can follow delay.

• Ratio. Tariff computations, DPRs for power projects, and consumer-meter records of KSEB are disclosable; internal cost sheets fall under §8(1)(d) with reasoning.
• PIO takeaway. Utility / DISCOM records are overwhelmingly in scope — §8(1)(d) applies narrowly.

• Ratio. The State Information Commission must issue reasoned orders; procedural compliance (hearing the PIO and applicant) is reviewable.
• PIO takeaway. SIC orders without reasoning are fragile; natural justice protections apply to both sides.

• Ratio. Post-graduate scoresheets and evaluator-assignment records must be segregated — scores are open, evaluator-identity is protected.
• PIO takeaway. Apply severability under §10 rather than denying the whole record.

1. “The Kerala High Court in Thalappalam set out the substantial-financing test — registration alone does not make a body a public authority.”
2. “In Treesa Irish, the Kerala High Court held that file-notings are part of the record under §2(i), subject to §8(1) line-by-line analysis.”
3. “In Velu v. State of Kerala, the Kerala High Court enforced the §7(1) proviso — life-and-liberty requests are bound to 48 hours.”

• Severability (§10) claims quote GMC Thiruvananthapuram to force partial disclosure instead of blanket denials.
• Life-and-liberty (§7(1) proviso) cases cite Velu v. State of Kerala for strict enforcement.
• Co-operative RTI debates cite Thalappalam on both sides — the PIO to resist, the applicant to prove substantial financing.

• Reading Thalappalam as a blanket exemption — it is a test, not a shield.
• Over-reliance on Treesa Irish — file-noting is disclosable, but §8(1) grounds still apply item-by-item.
• Skipping §10 severability — Kerala HC consistently favours partial over blanket denial.

• PIO / FAA knowledge base
• How to cite case law
• Bombay HC rulings
• Madras HC rulings
• Karnataka HC rulings
• Section 10 — severability

• Kerala High Court judgements (India Kanoon / KHC portal)
• Thalappalam Service Cooperative Bank Ltd. v. State of Kerala (2013) 16 SCC 82
• Kerala State Information Commission annual reports
• RTI Act, 2005

Last reviewed: 21 April 2026.