Canara Bank v. C.S. Shyam
Information about employees’ transfers, postings and service particulars is “personal information” under Section 8(1)(j). It is normally exempt. The Court decided this on the clause as it stood before 13 November 2025; the clause now reads only “information which relates to personal information”, and a public authority may still allow access under Section 8(2), or under the proviso to Section 11(1) for third-party records, where the public interest in disclosure outweighs the harm.
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; on the clause as it then stood, the larger-public-interest override had to be specifically pleaded and established. Since 13 November 2025 that argument sits in Section 8(2) or, for records relating to or supplied by a third party, the proviso to Section 11(1), and it still cannot be presumed.
To obtain personal or service information about others, set out expressly why the public interest in disclosure outweighs the harm, citing Section 8(2) and, for third-party records, the proviso to Section 11(1); 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 the public authority is satisfied, under Section 8(2) or the proviso to Section 11(1), that the public interest in disclosure outweighs the harm
- 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 public-interest case under Section 8(2) or the proviso to Section 11(1) is pleaded or proved
When to cite this case
When seeking or resisting bulk employee or service data, or to stress that the public-interest case under Section 8(2) must be specifically established, not assumed.
Later developments / current status
Statutory update: clause (j) was substituted with effect from 13 November 2025 by the Digital Personal Data Protection Act, 2023 (section 44) and now reads only “information which relates to personal information”, so this judgment construed wording that is no longer in the Act; the public-interest tests that remain are Section 8(2) and, for third-party records, the proviso to Section 11(1). Canara Bank v. C.S. Shyam reinforces Girish Deshpande on Section 8(1)(j) and is cited for the proposition that a public-interest case must be affirmatively made out on the record, not presumed.
Source & verification
Related FileMyRTI services
Use RTI Dost to draft a request that clearly sets out your public-interest justification.
Login With Google
Continue as Guest