Institute of Chartered Accountants of India v. Shaunak H. Satya
Instructions and model answers given to examiners and moderators can be withheld under Sections 8(1)(d) and (e) — but the RTI Act must be applied carefully so its purpose is not defeated, and what is sensitive before an examination may not stay exempt afterwards.
Issue before the court
Whether an examining body must disclose instructions and model answers issued to examiners and moderators, and how RTI exemptions apply to the examination process.
Facts in brief
A CA examinee sought, among other things, the instructions and model answers that ICAI gave to its examiners and moderators. ICAI resisted, claiming exemption.
Holding / decision
The Supreme Court held that instructions and model answers issued to examiners and moderators are exempt under Sections 8(1)(d) and (e). But it cautioned that the RTI Act should be applied so as not to defeat its object, and recognised a temporal dimension — information sensitive before an examination may lose that character afterwards.
Examination-process confidences can be protected under Sections 8(1)(d) and (e), but exemptions are to be construed so as not to defeat the RTI Act, and sensitivity can be time-bound.
You may get your evaluated answer book (see CBSE v. Aditya Bandopadhyay), but internal examiner instructions and model answers can be withheld — though timing matters, and post-examination disclosure may be possible.
What RTI can help you get
- Your evaluated answer book (per Aditya Bandopadhyay)
- Information whose sensitivity has lapsed after the examination
- Process information not genuinely covered by Section 8(1)(d) or (e)
What RTI may not give you
- Confidential instructions or model answers to examiners while genuinely sensitive
- Trade-secret-type process material under Section 8(1)(d)
- Material whose disclosure would harm the integrity of an ongoing examination
When to cite this case
When an exam body refuses examiner instructions or model answers, or when arguing that confidentiality lapses once the examination is over.
Later developments / current status
ICAI v. Shaunak Satya is regularly cited alongside Aditya Bandopadhyay to mark the line between disclosable answer books and protected examiner material. Its “do not defeat the Act’s object” caution is frequently invoked.
Source & verification
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