Are the Rights to Information and Privacy quintessentially needed in the
society? Are they absolute? Can they work in Harmony? Can they hold the test of
time and prove themselves to be dynamic?
This Article seeks to establish the intrinsic nuances of the Right of Privacy
and Right to Information. Though the Justice KS. Puttaswamy Judgement has
catered to the issue of Aadhar Card and Right to Privacy; it has still given
birth to many impending issues like the correlation and analysis of the Right to
Privacy and Right to Information Act, which is sought to be sorted.
Right to Information has been an aspect of immense grandeur right from its
inception. It sought not only to provide access of information to the
individuals from the control of Government authorities, but also promoted
information disclosure on a transparent scale. It has predominantly ensured that
the entities are answerable to the public and proved that for effective
functioning of the public authorities, efficient enforcement and disclosure
mechanism is important.
On the other hand, Right to Privacy has been held to be an implicit fundamental
right within the ambit of the Article 21 of the Constitution following the
landmark Justice K. S Puttaswamy v. Union of India. Both Right to Information
and Right to Privacy are recognised worldwide as fundamental and basic human
rights and have their own sets of origins and functions applicable.
Right to Information:
From the Official Secrets Act passed by the British Legislation, where the
citizens were supposedly granted the authority to access Information, to the
Right of Information Act, 2005, India has witnessed many high's and many low's.
The Change that has occurred, has given more authority and rights to citizens.
Right to Information forms part of Article 19 of Constitution which talks about
Freedom of Speech and Expression. Citizens' Right to know has been recognised
and the importance of express opinion about the idea of Democracy has been
The Act has been constructed in a wholesome manner by ensuring that the time
period necessary to provide information, the method of such provision and
exceptions, are addressed.
Right to Information Act has been said to be passed not only for accountability
but also to make sure that there is no secrecy in the functioning of the
Government. Awareness is considered an essential feature.
The Governments have been made responsible for providing the access of
information requisitioned by the citizens. The Public Authorities under the Act
are those established by the Government or under the Indian Constitution, by
Parliament, by Legislature of the State, notification or an NGO.
Right to Information is said to have originated from the freedom of expression
and is considered a backbone worldwide. It is needed and is essential for
smooth process of every democratic country. In a democracy, citizens
participate and adhere to the decision making process. For this to succeed,
there is a need for information on the policies brought in by the Government,
which can be achieved through Right to Information.
The Public authorities are to address the issue of imparting information within
a time period of 120 days and this has been mandated by Section 4 of the Act.
Bodies like the Central Information Commission and State Information Commission
have been established to resolve disputes filed by citizens on failure to access
The Act does not permit absolute disclosure, rather provides few exemptions to
disclosure under Section 8 of the Act. They include information from the public
authority need not be disclosedif it is of a nature that would put the safety of
a person at risk. If the information is of such a secretive nature that it will
endanger the security interest of the nation, then it is exempted.
Principles of Formulation include:
Elements of Right to Information include:
- Flow of information without any disturbance and in a fair manner.
- Co-relation with aspects of privacy and remove contradiction.
- Government accountability for any misuse or abrupt mishandling of
- Security to the individuals as an interest of the state.
Analysis of the Provisions:
- Every individual has an inherent right to seek information.
- This inherent right gives a corresponding duty to the respective entity to
provide the information within a reasonable time.
- Rights are always subject to exemptions. They generally include interests of
security and privacy, public order, information received on basis of trust.
- Bodies are set up to address the grievances of the citizens who allege that
information has been withheld.
The Act has come into force from the 21st of June 2005 and has received
President's Assent on 15th of June 2005.
The Preamble sets out to provide information access to the citizens subject to
no loss of confidentiality. It is made available to all citizens who want to
avail it and is considered essential to bring together the interests of those in
contradiction with each other.
Information under the Act refers to records, mails, advices, and others held
in physical form or electronic form which is under the public authority and is
Right to Information has been defined through a series of rights which
include the right to inspect the documents and materials, right to take the
material samples, right to obtain information in both electronic and physical
Public Information Officers have been accorded to make sure and to provide the
information sought by the citizens. Application seeking information can be
filed before the Central/ State Public Information Officer, Central/ State
Assistant Public Officer.
Complaint can be made to the Appellate Authorities citing withhold of
Information, fee amount not as per the provisions of the Act, inability to
register with the Public Information Officers.
Pritam Rooj v. University of Calcutta
 right to information is considered the
most basic. And it is an empowerment granted to the individual.
Right to Information- From the Fundamental Right perspective:
Freedom of press has been closely linked to the Right of Information as the
growth of Information, as a right begun with press. When the freedom of speech
and expression is curbed, then citizens' right to know is said to be enhanced as
they seek the reasons to such a curb.
A Case that has analysed the aspect of Information is Bennett Coleman v. Union
, where Information was said to be contained within Freedom of
Speech and Expression under Article 19 of the Constitution. In People's Union for
Civil Liberties v. Union of India
 and SP Gupta v. Union of India, it was analysed by the Hon'ble Court that there is a need for public to know the
details of the Acts done and measures undertaken by the Public Authorities.
In Re Raj Narain
, the Court has institutionalised that the right of the
citizens to know about every public act and though not absolute, it is a factor
of utmost importance. In Indian Express Newspapers v. Union of India
, It has
been stated that the fundamental structure of speech and expression is the right
to not only express views and opinions freely but also the right to know.
Secretary General of Supreme Court of India v. Subhash Chandra Agarwal
Respondent sought for declaration of assets and the court declared that the
information be made known. The Delhi High Court stated that any information
given by the Chief Justice of India is also a matter of public information and
if he has declared assets, then that it is treated as personal information and
dealt with under Section 8(1)(j) of the Right to Information Act.
To know the acts done by a candidate before elections can be considered to be a
fundamental right of the citizens who are voting under Article 19(1)(a) of the
Constitution. This is when the Right to Information is needed to the voters so
that he can be the final decider of who he wants to vote for and for whom he
Right to Information is said to benefit as:
It improves the reputation of the Government : Right to Information creates and
enhances citizen partnership with the Government. Welfare projects introduced by
the Government are made in collaboration with co-operative and other non- profit
organisations to improve government trust in people.
It provides corruption free service: If the information is made accessible to
all citizens, then there is absence of misuse of power and increase in
transparency of the Government Authorities. Administration is made without any
ulterior motives and achieves efficiency.
Enables the citizens to get access to information and thus, advocate for
themselves. It helps people for information about centres, states and also non-
Discomforts present in the Act:
In a country that has been long affected by levels of illiteracy, it is
important that the purpose of legislations like the Right to Information Act, be
made known. Mere introduction and passing of the Act as a legislation, is not
The authorities are required to ensure that public awareness is made in each and
every rural area and, if there is no access to electronic medium, then there is
a necessity to physically explain to the citizens in that area.
In the Right to Information Act, 2005, exemptions cross the necessary borders,
as restrictions have also been placed on records of cabinet, which encourage
them to withhold information. It is a sine qua non function that is given the
most priority in a democratic country.
Right to Privacy
Privacy is that right of an individual that his/her personal data belongs to
that individual and not made use of by any other entity or person unless the
individual consents to the same. Black's Law Dictionary has summed privacy to be
letting the person alone and non- interference into a person's life.
Privacy provides an aspect of control to the individual and is all about
confidentiality of information whether useful or not. It ensures autonomy and
feeling of safety to individuals. Right of Privacy does not stop only with
unwarranted interference, it also holds within it, the protection of data from
strangers, trespassers and also lawyer-client confidentiality.
Universal declaration of Human rights has analysed that no one should
interfere into another person's property or personal matters. International
Covenant of Civil and Political Rights states that the concept of privacy is
unlawful and no one shall be allowed to interfere. European Convention on Human
Rights states that no one shall interfere if the public is not affected and
unless such interference brings out protection of morals of a healthy society.
The Right to Privacy is an uncontested right of a person which is combined with
the right of life and personal liberty of an individual. It is in question only
when the meaning tends to be altered or when it is mishandled by individuals on
the wrong side of law. Right to Privacy is protected under Article 21 of the
Constitution, which provides that no person shall be striped off life except
under procedure established by law.
It is the right that provides an individual freedom for being intruded at by the
public. However, this is not an absolute right and imposition of restrictions
are allowed. These restrictions have been placed to fulfil the provisions of
Directive Principles of State Policy enunciated in the Constitution.
Right to Privacy has been brought down essentially from damages through private
action for intrusion of privacy being maintainable and through Right to Life and
Personal Liberty from the Constitution.
This right of privacy generally tends to supersede the liberty concept as there
is a difficulty to analyse the ambit of this right.Right to Privacy is not an
explicit provision in the Indian Constitution but is a matter of law that has
originated from the precedents.
It is a basic right that seeks to preserve the personality and own works of
individuals and it has now attained popularity as the 'right to be left
In Kharak Singh v. State of Uttar Pradesh
, the Supreme Court recognised the
right of privacy and observed it to be implicit in the provisions of the
Constitution. However it did not successfully contest that Privacy is a
fundamental right and declared it was not.
In Govind v. State of Madhya Pradesh
, it was decided that the right
to Privacy is subject to compelling interest and that it was based on the
assumption that privacy is a fundamental right. It was held to be prominent and
integral to upkeep the structure of Article 21 of the Constitution.
It is said that if there occurs an invasion of privacy, then it can be subjected
to a veil provided that the commission of the offence is made by the State and
not an individual. In Rajagopal v. State of Tamil Nadu that publication
in any form without the express consent of the individual is considered an
invasion of privacy and it is irrespective of whether it is the truth or
Justice Puttaswamy v. Union of India
, the main issue was revolving around
whether the Aadhar scheme was violative of the Right to Privacy and whether it
is an inherent fundamental right or not. The Court, through a nine-judge bench
decided that Privacy is a Fundamental right and is contained within the ambit of
Section 21 of the Constitution.
In Selvi v. State of Karnataka
, the Supreme Court established and made known
that there is a difference existent between physical and mental privacy and this
act of segregation is important.
In People's Union for Civil Liberties v Union of India
privacy was analysed. The Analysis was laid down as intercepted communication is
integral and must be passed in the order specified.
In Sharda v. Dharmpal
Right to Privacy was not an absolute right and that the right which provides
greater interest will prevail over the lesser one.
In State of Maharashtra v. Madhukar Narayan Mardikar
, it was held that just
because a woman is a prostitute, does not mean she is not entitled to the right
of privacy. No one can intrude into her privacy and cannot contend that she is a
woman of easy virtue. In Ram Jethmalani v. Union of India
, it was decided
that the Right to Privacy, even though an integral one, it is important that
humans be allowed the process of judicial check over all acts.
Government's intrusion can also be made subject to an in depth analysis of the
case. In Unique Identification Authority of India v. Central Bureau of
Investigation, CBI sought for access of the Unique Identification Authority
database which was ruled against by the Supreme Court of India. It was observed
that no information can be transferred, even by Government entities without the
prior consent of the individuals who are the owners of that information.
In today's technologically advanced era, there is a possibility of million cyber
crimes like theft of personality, online victims, cyber stalking, cyber
bullying, cyber pornography etc which is why the importance of Right to
Information and Right to Privacy must be highlighted.
The factors that are to
contain in every state that assures its individuals on presence of privacy are:
Bill on Right to Privacy:
- Assure that invasion into individual's affairs will be eradicated.
- Disclosure of private information will not be made on a public forum.
- If there is a possibility of monetary or advertising advantage, the
information will not be misused.
This Bill promotes individual's privacy at basic fundamental levels like e-mails
forwarded or received, conversations made through telephones, and amenities or
facilities availed like medical or financial services.
Privacy is not only considered subject to the limitations of crime prevention,
public chaos etc but also arises out of relationships that have been created out
of marriage, politics etc. It is also not restricted to a mere right but is also
connected to Right of Dignity as enunciated in Article 21 of the Constitution.
It safeguards and protects parts of family, love, marriage that are necessary
to bind the society to its traditional roots. It can be said that while defining
privacy, Supreme Court did not leave a stone unturned and confidentiality as an
integral aspect was well established by the Judiciary to the Individuals.
Relationship Co-existing between Right to Information and Right to Privacy
In today's scenario, there is more focus on the concept of data protection, data
localization, however, it must be realised that for achieving technological
advancements, it is important that first, the future of Privacy and Right to
Information is essential and needs to be analysed through a broader
Right to Information and Right to Privacy complement each other, more often than
not. Both the rights provide access of personal information. Issues between the
Right of Information and Right of Privacy can be mitigated through application
of better definitions, better measures adopted and clarity in bifurcation.
Appropriate tests to determine public interest may be adopted thus striking a
common cord between the rights. The relationship between Right to Information
and Right to Privacy cannot be resolved in a straightforward manner but must be
analysed according to a case by case understanding and resolution thereafter.
The right to Information and Right to privacy can be analysed through the
- Information Freedom:
Information can be analysed as improvement in
disclosure, citizens can put forward better views on the policies formulated by
the Government and Government undertaken processes are conducted in a just
Privacy holds that information shared for a particular purpose must be utilised
for the said purpose and if required to be utilised for a different purpose,
then consent for the same is necessary.
Modern measures adopted by the Government can however contradict itself with the
traditionally existent measures and this is made effective by Right to Privacy
which links personal power of the citizens who are in complete control of
- Is the Right to Information in conflict with Right to Privacy:
When the Government collects information from the citizens for different
purposes like for tax evaluation, Identification Proofs, then if any citizen
files for access to the records, then it is in contradiction with each other
as the citizens'
Right to Privacy is violated if Right to Information is followed.
- Analysis of Section 8(1)(j) of the Right to Information Act, 2005:
If the information sought to be declared by the citizens cannot be disclosed
because it affects the interests, security of the nation or for preserving
confidential information that is sensitive, then the Personal Information is
- Contradiction between Right to Information and Right to Personal
This contradiction tends to occur when a citizen seeks personal information
relating to a third party. In this case, there is a clash and there exists a
need to strike a common cord between the two. This came up as a major issue
while framing Section 8(1)(j) of the Right to Information Act as disclosure
can not be granted on the grounds of information of a personal nature being
made known if it intrudes into the privacy of the individual.
In a complementary manner, it can be stated that Right to Privacy and Right to
Information mutually enhance and provide access individually to personal
information. The Rights are not considered to be distinct but form a part of
complete development and information policy. It is considered that the
habeas data (Right to obtain Information) in the data bases can be in a way held
accountable in many countries. Laws of Privacy can be used for information
if there is no Information Law and Information Law can be used to improve the
existing privacy law.
Privacy of Information is essential as it allows for exercise of autonomy over
people. Privacy and preservation of information is mandatory for its orientation
towards achieving a better educated society. Person can enhance on the benefit
of sharing limited to a particular sphere, without worrying on spread of the
Conflict between the Right of Information and Right of Privacy is said to be in
question due to misunderstandings that ought to be protected.
Does Public interest triumph over Privacy:
In any given scenario and given case, it is popular subject matter that if it
can be proved that the public interest succeeds the need for privacy, then
information can be made available. Line can be drawn between private and public
servants where public interest is of a higher degree in the latter.
When there is a clash between Right to Information and Right to Privacy, the
former will prevail as it leans towards providing an interest to all and not
A precedent in this regard includes Surup Singh Hrya Naik v. State of
Maharashtra, where the Bombay High Court laid mechanisms to be met before
the information can be made known regarding third party. It has stated that
there always exists a clash between the individual who wants to keep his affairs
secret and public who wants to be informed. It is contended by individuals that
if the information is disclosed, it might lead to misuse, however if the
information falls within the exemptions of the Right to Information Act then it
will not be disclosed by the concerned authorities, so it can only be fair to
say that only information that serves a larger public interest is disclosed and
there is no point of contention of misuse made by the individuals.
The records of the public servant are those made in exercise of his
administration of public affairs and hence it comes within the purview of public
interest and not private interest.
The Relationship can also be analysed through the public interest of patients,
and the secrecy around medical research and records. In Arjesh Kumar Madhok v.
Centre for Fingerprinting and Diagnostics
, the Central Information
Commission upheld that the medical testing and the purpose and results were not
to be disclosed under the Right to Information Act as personal details of
medical records had no scope of public interest and also as it would cause
breach of privacy of the individual. The people who want to access the
information do not have public interest, but even if they have an honest right
to know, the disclosure is not to be made.
If there is health and protection of individuals with risk of public involved,
then there might be justification for invading the patient's privacy. If however
a breach must take place, then the invasion must be limited. If for example,
there is a need for communication of a person's disease which is communicable,
then it must at the maximum be made known to the close family and not to the
Patients who have no monetary basis, may seek treatment in
government hospitals and not concentrate on right of privacy, owing to
non-application of the Right to Information Act. There is a reason to now
include those interests that are applicable beyond the health and protection of
public. Medical Code of Ethics Regulations prescribes that confidentiality is to
be maintained in regard of a patient and the doctor is not to disclose the
condition of the patient unless in a court or when there is a risk to the entire
community as a whole.
The Right to Information does not grant the right to plead for information about
individuals that is within trust based, unless and until public interest
overgrow the need for private interest of individuals. The extent of Right to
Information depends on the public interest and as unwarranted invasion of
Aspects of Right to Information Act are in understanding with the values of
safeguarding the aspect of privacy.
It is evident that now all Public Authorities' records must be disclosed for
public interest. However the term public interest has a huge scope and thus, the
concept of analysis would be whether Right to Information has a wider ambit or
more capacity than that of Right to Privacy.
Relation Post Justice Puttaswamy Judgement:
The part of Personal Information is said to have a possibility of being affected
as there have been different meanings assigned to the same. Justice Bobde has
defined it in the context of state surveillance as it is the revelation of one's
health, location etc to make sense of financial and personal well-being.
Separate suggestions and recommendations by the Judges have agreed on the
harmony between the Right to Information and Right to Privacy.
Justice Chandrachud opined that protection requires constitutional right to be
implemented through the laws protected. Right to Information Act exempts that
information which create intrusion into privacy of an individual. Justice
Nariman observed that through Section 8(1)(j) of the Right to Information Act,
2005 the Right of Privacy has been recognised by the Legislature.
In Bihar Public Service Commission v. Saiyed Hussain Abbas Rizwi
, it has
been held by Justice Kumar that public interest is the factor that must be kept
in mind while striking the balance between Right to Information and Right to
Privacy. Serving larger public interest is important especially when
constitutional values are imparted.
The concept of public interest can be summed up as:
- Personal information must be analysed by way of public interest
- Personal Information must be such that the disclosure should not cause
intrusion of privacy.
- Right to Privacy can be relaxed when a larger public interest is in
Right to Information and Right to Privacy are used to promote and provide the
global mark of India and it is brought to the notice of the global forum that
requirement of increasing sensitivity in access of records is a necessity to be
Dr. Manmohan Singh has expressed an opinion that there exists harmony between
Right to Information and Right to Privacy and the point of conflict arises when
there is no consensus on where to draw the line between the two rights.
Right to Information provides access, while privacy curbs and covers
it. Experience has been narrated to be that when it comes to enforcement of Right
to Information Act, then there has been lacuna in its implementation and denial
to disclose information is at its peak.
Predominance of Corruption and conflict of interest between both the citizens
and public authorities may result in a chaotic understanding of the two and to
establish Right to Information's relationship with right to Privacy.
As an individual with a complex society, it might not seem that a right to
privacy and information is needed, however it is integral to a functioning
society and it is that right that sets humans apart from what is called , a mere
existence of an animal. However, it is a must say that the limits within which
it is subjected to is made known to the same individuals to prevent misuse.
Every step while safeguarding privacy must be treaded carefully and with utmost
precaution as a single mistake can put an end to million lives of the
Thus, the point of whether the rights can work in harmony or are always at
loggerheads depends on the awareness of the State and its duty to codify laws
and regulations that promote common understanding between the two.
Written By: V. Krishna Laasya,
- Justice K.S. Puttaswamy v. Union of India, 2017 (10) SCALE 1,2017 10 SCC
1, WP (C) No. 494/2012. Coram- Justice DY Chandrachud, Justice Jagdish Singh
Khehar, Justice Abdul Nazeer, Justice S. Bobde, Justice Jasti Chelameswar,
Justice Rohinton Nariman, Justice Abhay Sapre, Justice Sanjay Kishan Kaul.
- For Consolidation and Amendment of the Act in light of official secrets
and access to citizens, see Official Secrets Act, 1923- Act No. 19 of 1923
passed on 2nd April 1923. Available at <https://indiacode.nic.in/bitstream/123456789/2379/1/A1923-19.pdf>.
last accessed 11 May 2020.
- Right to Information Act, 2005 is applicable to Central, State
Governments and Public Authorities. Public Authorities have been defined
under Section 2(h) of the Aforesaid Act.
- For freedom of expression, Article 19 of the Universal Declaration of
Human Rights. For International Standards on Right to Information, Mendel
(2008) and Banisar (2006).
- Right to Information is “Requisite for the very exercise of democracy”,
OAS 2003. In 2006, Inter- American Court of Human Rights held that State's
actions are governed by disclosure policy.
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last accessed- 12 May 2020
- Right to Information in Consonance with Right to Privacy by Vratika
Phogat. Last accessed- 12 May 2020.
- Section 2(f) of the Right to Information Act, 2005.
- See Section 2(j) of the Right to Information Act, 2005.
- Section 2(5)(1) of the Right to Information Act, 2005.
- Pritam Rooj v. University of Calcutta AIR 2008 Calcutta 118, WP No.
22176 of 2007
- Bennett Coleman v. Union of India, AIR 1973 SC 106.
- People's Union for Civil Liberties v. Union of India, 2003 SCW 2353 SC
- SP Gupta v. Union of India, AIR 1982 SC 149.
- State of Uttar Pradesh v. Raj Narain AIR 1975 SC 865
- Indian Express Newspapers v. Union of India, 1985 1 SCC 641
- Secretary General, Supreme Court of India v. Subhash Chandra Agarwal,
High Court of Delhi LPA No. 501/2009
- Section 8(1)(j) of the Right to Information Act, 2005 relates to
information of personal nature does not warrant for disclosure unless there
is a greater public interest involved.
- For the analysis and source of Benefits, see Implementation of Right to
Information and Impact on Administration. Research Report submitted to
Department of Personnel and training- RTI Fellowship Report, 2015 by
Dharanesha ST. last accessed- 12 May 2020
- Article 12 of the Universal Declaration of Human Rights (1948)
- Article 17 of the International Covenant on Civil and Political Rights
(16 December 1966)
- Article 8 of the European Convention on Human Rights (signed- 4 November
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- Rajagopal v. State of Tamil Nadu, 1995 AIR 264, 1994 SCC (6) 632
- Supra Note 1.
- Selvi v. State of Karnataka, (2010) 7 SCC 263.
- People's Union for Civil Liberties v. Union of India, AIR 2003 SC 2363.
- Sharda v. Rampal, 2003 4 SCC 493
- State of Maharashtra v. Madhukar Narayan Mardikar , 1991 1 SCC 57
- Ram Jethmalani v. Union of India , 2011 8 SCC 1
- Unique Identification authority of India v. Central Bureau of
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B. Com. LL. B (Hons.), School of Excellence in Law, Tamil Nadu Dr. Ambedkar Law University