CBSE v Aditya Bandopadhyay

• Aditya Bandopadhyay (student) sought copy of his evaluated CBSE answer sheet under RTI Act
• CBSE refused: argued answer sheets are "fiduciary" information (S.8(1)(e)) and disclosure would disrupt examination system
• Central Information Commission directed disclosure
• CBSE appealed to courts

1. Whether evaluated answer sheets constitute "information" under S.2(f) of RTI Act?
2. Whether S.8(1)(e) (fiduciary relationship) exempts answer sheets from disclosure?

• Answer sheets ARE "information" under S.2(f): "any material in any form" includes evaluated sheets
• Relationship between examiner and CBSE is NOT fiduciary; it is contractual/professional
• S.8(1)(e) does not apply; disclosure must be granted
• However: SC cautioned that RTI is a means to achieve good governance and transparency, not a tool to obstruct government functioning
• Directed reasonable fee for photocopying; discouraged mass/frivolous applications

The RTI Act's definition of "information" (S.2(f)) is extremely broad: "any material in any form held by a public authority." Evaluated answer sheets clearly fall within this. Exemptions under S.8 must be strictly construed (being exceptions to the fundamental right to know). The examiner-Board relationship is professional/contractual, not fiduciary (which requires highest obligation of trust like trustee-beneficiary).