Canara Bank v. C.S. Shyam
Information about employees’ transfers, postings and service particulars is “personal information” under Section 8(1)(j). It is exempt unless the applicant specifically establishes a larger public interest in disclosure — which cannot be assumed.
Issue before the court
Whether bulk information about the transfers and postings of a bank’s employees can be obtained under RTI, or whether it is exempt personal information under Section 8(1)(j).
Facts in brief
The applicant sought extensive details — across many parameters — of the transfers and postings of all clerical staff across the bank’s branches over several years, including joining dates, promotions and the authorities who issued the transfer orders.
Holding / decision
The Supreme Court held that this information pertained to individual employees and was therefore “personal information” under Section 8(1)(j). Since the applicant neither asserted nor established any larger public interest, and neither the CIC nor the High Court recorded such a finding, the information was exempt and need not be disclosed.
Service particulars of employees are personal information; the larger-public-interest override under Section 8(1)(j) must be specifically pleaded and established — it cannot be presumed.
To obtain personal or service information about others, clearly set out and justify the larger public interest in your RTI; a bare request for bulk staff data will be refused.
What RTI can help you get
- Your own service and transfer records
- Personal information about others where you specifically establish a larger public interest
- Aggregate or policy information that does not single out individuals’ private particulars
What RTI may not give you
- Bulk transfer or posting data of employees without a public-interest justification
- Another person’s service particulars by default
- Personal information where no larger public interest is pleaded or proved
When to cite this case
When seeking or resisting bulk employee or service data, or to stress that the larger-public-interest override must be specifically established, not assumed.
Later developments / current status
Canara Bank v. C.S. Shyam reinforces Girish Deshpande on Section 8(1)(j) and is cited for the proposition that the public-interest override must be affirmatively established by the applicant.
Source & verification
Related FileMyRTI services
Use RTI Dost to draft a request that clearly sets out your public-interest justification.
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