Delhi High Court Quashes CIC Order on PM Modi’s Degree Disclosure, Citing Privacy Concerns
New Delhi, India – August 25, 2025 – The Delhi High Court, in a significant ruling, set aside a 2016 order by the Central Information Commission (CIC) directing Delhi University (DU) to disclose details of Prime Minister Narendra Modi’s 1978 Bachelor of Arts (BA) degree. The single-judge bench of Justice Subramonium Prasad, in its verdict on August 24, 2025, upheld DU’s appeal, citing privacy concerns and the irrelevance of the degree details to public interest under the Right to Information (RTI) Act, 2005. The decision, reported by The Hindu, Indian Express, and Times of India, marks the latest chapter in a nearly decade-long controversy over the authenticity of Modi’s academic credentials, reigniting debates over transparency, privacy, and political accountability.
Background of the Case
The controversy began in 2016 when Arvind Kejriwal, then Delhi Chief Minister and Aam Aadmi Party (AAP) chief, raised questions about the authenticity of PM Modi’s BA degree from DU and his MA degree from Gujarat University. Kejriwal’s allegations, amplified by an RTI application filed by advocate Neeraj Kumar, prompted the CIC to order DU and Gujarat University on April 29, 2016, to provide access to Modi’s degree records, including enrollment details, results, and verification processes. The CIC, led by then-Information Commissioner M. Sridhar Acharyulu, argued that public interest in the educational qualifications of a sitting Prime Minister outweighed privacy concerns.
DU challenged the CIC order in the Delhi High Court, arguing that disclosing personal academic records violated privacy rights and that the information was not maintained in a manner accessible for public inspection under Section 8(1)(e) of the RTI Act, which exempts information held in a fiduciary capacity. The university also contended that the CIC’s directive exceeded its jurisdiction and failed to establish a public interest necessitating disclosure. In 2018, the court stayed the CIC order pending a final decision, and after multiple hearings, the case culminated in the August 24, 2025, ruling.
Delhi High Court’s Verdict
Justice Subramonium Prasad, in a 40-page judgment, quashed the CIC’s 2016 order, ruling that the disclosure of PM Modi’s degree details was an “unwarranted invasion” of privacy under Section 8(1)(j) of the RTI Act, which protects personal information unless it serves a larger public interest. The court noted that DU had already provided sufficient evidence of Modi’s degree through public statements and documents released in 2016 by BJP leaders, including then-party president Amit Shah and Finance Minister Arun Jaitley, who displayed copies of Modi’s BA and MA degrees at a press conference.
The court emphasized that academic records, even of a public figure, constitute personal information. “The information sought regarding the educational qualifications of the Prime Minister is not of such public interest that it outweighs the individual’s right to privacy,” Justice Prasad observed, as quoted by LiveLaw. The judge further noted that the RTI applicant failed to demonstrate how the disclosure would advance public interest, especially given that Modi’s degrees had been publicly verified by DU and Gujarat University in 2016.
The ruling also addressed the CIC’s overreach, stating that the commission’s directive to allow inspection of all 1978 BA records was disproportionate and impractical, as DU’s records were not digitized or maintained for such purposes. The court found no evidence of malafide intent in DU’s refusal to comply, reinforcing that universities hold student data in a fiduciary capacity, exempt from mandatory disclosure under the RTI Act.
Political and Public Reactions
The verdict has elicited sharp reactions, reflecting the polarized discourse surrounding Modi’s academic credentials. The BJP hailed the decision as a vindication, with spokesperson Sambit Patra accusing the AAP of running a “malicious campaign” to defame the Prime Minister. “Kejriwal’s obsession with Modi’s degree has been put to rest by the court,” Patra told NDTV, urging the AAP to focus on governance issues.
Kejriwal, in a press conference reported by India Today, criticized the ruling, arguing that it undermines transparency. “If the PM’s degree is genuine, why fear disclosure? This raises more questions than it answers,” he said, reiterating his 2016 claim that discrepancies in Modi’s degree, such as inconsistencies in roll numbers and nomenclature, warranted scrutiny. AAP supporters on X, including @AamAadmiParty, echoed this sentiment, alleging that the verdict “protects opacity over accountability.”
The Congress, through spokesperson Jairam Ramesh, took a more measured stance, noting that while privacy is a valid concern, public figures should voluntarily disclose such details to maintain trust. Posts on X, such as by @IndianExpress, described the ruling as “a setback for RTI activists,” while @TheWire_in highlighted the ongoing public curiosity about Modi’s qualifications, with some users questioning why the PM did not proactively release detailed records to end the controversy.
Context of the Controversy
The debate over Modi’s degrees began in 2015 when Kejriwal, citing an RTI response, alleged that Modi’s BA degree from DU was unverifiable and that his MA degree from Gujarat University listed him as an “external candidate” with questionable records. In response, DU and Gujarat University released documents in 2016 confirming that Modi graduated with a BA in Political Science in 1978 (third division, 165/400 marks) and an MA in Political Science in 1983 (first division). Despite this, skepticism persisted, fueled by discrepancies in degree formats and Kejriwal’s claim that Modi’s name appeared as “Narendra Damodardas Modi” in some records but “Narendra Kumar Modi” in others.
The controversy has been a political lightning rod, with the AAP leveraging it to question Modi’s credibility, while the BJP dismissed it as a distraction from governance issues. The Delhi High Court’s 2018 stay on the CIC order had temporarily paused the matter, but the 2025 ruling effectively closes this chapter, unless challenged in the Supreme Court.
Legal and Policy Implications
The verdict reinforces the judiciary’s stance on balancing RTI disclosures with privacy rights, aligning with precedents like Central Public Information Officer v. Subhash Chandra Agrawal (2019), which limited the scope of personal information disclosures. Legal experts, quoted by LiveLaw, noted that the ruling clarifies that public interest must be substantial and specific to override privacy exemptions under the RTI Act. This could impact future RTI requests targeting public figures’ personal records, such as academic or financial details.
However, RTI activists expressed concern that the decision could deter transparency efforts. Prashant Bhushan, an advocate and RTI campaigner, argued on X that “public figures like the PM should be open to scrutiny, especially when doubts persist.” The ruling may prompt petitioners to appeal to the Supreme Court, though DU’s compliance with earlier verifications strengthens its legal position.
Broader Significance
The case highlights the tension between transparency and privacy in India’s democratic framework, particularly for high-profile leaders. The controversy, while centered on Modi’s degrees, reflects broader questions about political accountability and the role of RTI in public discourse. The BJP’s 2016 disclosure of Modi’s degrees, coupled with the court’s ruling, may quell some speculation, but the polarized reactions suggest that the issue will remain a point of contention.
As India approaches key state elections, including in Uttar Pradesh and Punjab in 2026, the verdict could influence political narratives, with opposition parties potentially framing it as evidence of institutional opacity. For now, the Delhi High Court’s decision marks a legal win for DU and the BJP, reinforcing the boundaries of personal privacy under the RTI Act while leaving room for continued public debate.
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