Summary
The Supreme Court set aside directions requiring UPSC to disclose examination information mechanically, holding that transparency must be balanced against examination integrity, confidentiality and efficient use of public resources. The Court accepted the concerns about disclosure of raw marks in the Civil Services examination, while preserving disclosure where public interest is established on the facts or an applicable rule or practice requires it. The unsuccessful candidates could approach an appropriate forum on those parameters.
Issues
- Whether Civil Services examination information could be ordered disclosed without considering competing public interests.
- How the RTI scheme and the examination-specific concerns should be balanced.
- Whether a properly supported request for disclosure remained open.
Held
- The RTI scheme required a purposive balance between transparency and accountability and other public interests, including efficient government operations, fiscal resources and sensitive-information confidentiality. The High Court had not applied those parameters. (¶¶ 5, 6, 7)
- The Court considered the UPSC evaluation concerns discussed in Prashant Ramesh Chakkarwar, including intermediate marks, moderation, examiner anonymity and system integrity. It held that raw-mark disclosure in this setting would cause the identified problems and was not to be directed mechanically; other academic examinations might stand differently. (¶¶ 8, 9, 10)
- Disclosure could nevertheless be required where public interest was established in a particular factual situation. An applicable rule or practice requiring disclosure could also be enforced. The decision did not create an absolute exemption from every request concerning examination information. (¶ 10)
- The impugned directions were set aside and the writ petitions dismissed, without barring the candidates from making out a case on the stated parameters before the appropriate forum. The connected appeal and special leave petitions were disposed of in the same terms. (¶¶ 11, 12, Connected matters)
Result
Impugned orders set aside and writ petitions dismissed, with liberty to pursue a case under the stated public-interest parameters. Appeals and connected special leave petitions disposed of accordingly.