The Delhi High Court has held that a wife cannot invoke the Right to Information (RTI) Act, 2005 to access her husband's Income Tax Returns (ITRs) for use in matrimonial and maintenance proceedings.
Justice Purushaindra Kumar Kaurav observed that income tax records constitute "personal information" and are protected from disclosure under Section 8(1)(j) of the RTI Act. The Court emphasized that matrimonial disputes do not automatically create a larger public interest capable of overriding an individual's right to financial privacy.
The case arose from a challenge to an order of the Central Information Commission (CIC), which had directed the Income Tax Department to disclose the husband's net taxable income to his wife. The husband approached the Delhi High Court seeking quashing of the CIC's order.
Allowing the petition, the Court held that disclosure of income tax information through the RTI mechanism would amount to an unwarranted invasion of privacy. It noted that the RTI Act is intended to promote transparency and accountability in public authorities and cannot be used as a tool for obtaining private financial information in personal disputes.
The Court further clarified that parties involved in matrimonial litigation already have adequate legal remedies available under family and maintenance laws. Courts hearing maintenance and matrimonial matters possess the authority to direct financial disclosures and obtain affidavits of assets and liabilities from the parties concerned.
Referring to established legal principles on privacy and information disclosure, the Court concluded that income tax returns remain exempt from disclosure unless a clear case of larger public interest is demonstrated. Since the dispute was purely matrimonial in nature, the requirement of larger public interest was not satisfied.
Accordingly, the Delhi High Court set aside the CIC's order and reaffirmed that personal financial records, including Income Tax Returns, enjoy statutory protection under the RTI framework.
The ruling is expected to have significant implications for matrimonial litigation, reinforcing privacy protections while directing litigants to rely on procedural mechanisms available under family law rather than seeking financial information through RTI applications.