HomeRTI Case-Law Library › Khanapuram Gandaiah v. Administrative Officer
File notings / records

Khanapuram Gandaiah v. Administrative Officer

Quick answer

RTI gives you access to information that already exists in the records of a public authority — documents, file notings, opinions, orders. It does not entitle you to demand the reasons for why a decision was taken, or answers to hypothetical questions.

Court / forum
Supreme Court of India
Citation
(2010) 2 SCC 1 · AIR 2010 SC 615
Decided
4 Jan 2010
RTI sections
2(f), 2(j), 6

Issue before the court

Whether an applicant can use the RTI Act to require a public authority to give the reasons for a decision, as opposed to seeking existing recorded information.

Facts in brief

The applicant sought to know why a judicial officer had decided his matter in a particular way — effectively asking for the reasoning behind a decision through an RTI application.

Holding / decision

The Supreme Court held that “information” under Section 2(f) means material that already exists and is held in the records of a public authority. An applicant can obtain existing records — opinions, advices, circulars, orders and file notings — but cannot demand that the authority explain why such a decision or opinion was formed, especially in judicial matters.

The RTI principle it set

RTI is a right to access existing recorded information, not a right to compel a public authority to create answers, give reasons, or justify its decisions.

What it means for you

Frame your RTI to ask for documents and records that exist — file notings, orders, correspondence. Do not ask “why” a decision was made; instead seek the records that reveal the reasons.

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What RTI can help you get

  • Existing records, documents, file notings, opinions and orders held by the authority
  • Copies of correspondence and recorded material
  • The recorded basis of a decision, where it exists on file

What RTI may not give you

  • An explanation of why a decision or opinion was formed
  • Answers to hypothetical or argumentative questions
  • Information the authority would have to create afresh to respond

When to cite this case

When an RTI is refused as seeking “reasons” or opinions, to draw the line between accessible records (including file notings) and impermissible “why” questions.

Later developments / current status

Khanapuram Gandaiah is routinely cited to reject “why”-type and argumentative RTI queries, while the right to existing file notings and records continues to be recognised.

Limits / caution: The case does not exclude file notings — those are existing records and are accessible; it only bars demands for reasons or clarifications that are not recorded information. Phrasing matters: ask for the record, not the rationale.

Source & verification

Primary official source: Official government source — pending verification
Full-text reference: Read the full judgment (free third-party legal database — not an official record)
Reviewed by
Adv. Syed Musab Rahim Hashmi
RTI Advocate · FileMyRTI Legal Team
Review status: Verified
Last reviewed: 25 June 2026
Source verified against: Pending official source

Related FileMyRTI services

Use RTI Dost to phrase your request as a record-based RTI that authorities cannot reject as a “why” question.

This is educational information, not legal advice. This summary is for general understanding of the Right to Information Act, 2005. The authoritative text is the official judgment as recorded by the court. Any third-party links are provided only for convenient reading. For your specific matter, consult a qualified legal professional.
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