RBI vs Jayantilal N Mistry case summary
RTI vs Reserve Bank of India
Supreme Court RBI RTI judgment
RBI fiduciary relationship and RTI Act
RTI disclosure bank inspection reports
banking secrecy vs public interest
Case Summary: Reserve Bank of India vs Jayantilal N. Mistry & Others
Citation: (2015) 12 SC CK 0018 | (2016) 3 SCC 525
Case No: Transferred Case (Civil) Nos. 91–101 of 2015
Date of Decision: 16 December 2015
Bench: Hon'ble Mr. Justice M. Yusuf Eqbal and Hon'ble Mr. Justice C. Nagappan
Final Decision: Petitions Dismissed
[Judgment Source]
https://www.courtkutchehry.com/Judgement/Search/AdvancedV2?docid=997118
Law Points Raised:
- RTI Act, 2005 – Sections 8, 10, 22 – Scope and limits of disclosure by public authorities, especially exemptions under fiduciary and economic interest clauses.
- Constitution of India – Articles 14, 19(1), 21 – Right to information as a fundamental right aligned with transparency and accountability.
- RBI Act, 1934 – Section 45E – Protection of confidential information.
- Banking Regulation Act, 1949 – Sections 27, 28, 35 – RBI’s statutory role in inspection and its claim of fiduciary obligations.
- Public Interest vs. Fiduciary Relationship – Whether the public interest overrides confidentiality between RBI and regulated banks.
Ratio Decidendi:
- The Right to Information is a constitutional right under Article 19(1)(a), and the RBI being a public authority cannot withhold information unless explicitly exempted.
- Exemptions under Section 8(1)(a), (d), and (e) of the RTI Act must be narrowly construed and subject to a test of overriding public interest.
- RBI’s supervisory role and inspection reports cannot be shielded on grounds of fiduciary relationship when the larger public interest in transparency outweighs confidentiality.
- The RBI and other banks have no fiduciary relationship with the inspected entities in a manner that can restrict public access to their reports.
Final Ruling:
- The Supreme Court upheld the orders of the Central Information Commission (CIC) directing disclosure of bank inspection reports and information.
- RBI’s contention of fiduciary confidentiality was rejected.
- The Court directed RBI to act with transparency and to disclose the information under the RTI Act unless it fell under a specific exemption that could withstand public interest scrutiny.
Relevant Paragraph Highlights:
- Para 1–3: Background of the transferred cases and CIC orders.
- Para 13–21: RBI’s inspection-based refusal of information and CIC’s direction to disclose.
- Para 22: RBI’s primary arguments on fiduciary obligations and statutory responsibilities.
- Para 35 onward (not detailed in excerpt): Reasoning for balancing confidentiality with public accountability.
Conclusion:
This landmark judgment firmly placed transparency over secrecy in public financial institutions. The Supreme Court emphasized that the Reserve Bank of India cannot deny information sought under RTI by citing fiduciary relationship or economic interest, when public interest in disclosure outweighs such concerns. It reinforced the role of the RTI Act as a tool of accountability in India’s financial governance.