Delhi HC sets aside CIC order on PM's IAF travel records under RTI
Synopsis
The Delhi High Court has ruled that disclosing details of Prime Ministerial foreign travel on IAF aircraft — even in redacted form — could enable adversaries to reconstruct security arrangements. By barring the CIC from second-guessing security agencies, the judgment sets a clear precedential limit on RTI's reach over VIP protection logistics.
Key Takeaways
The Delhi High Court on 15 October 2026 set aside a CIC order directing the IAF to disclose PM foreign travel records under the RTI Act .
Justice Amit Mahajan held that IAF was justified in invoking exemptions under Sections 8(1)(a) and 8(1)(g) of the RTI Act, 2005.
The court ruled that even redacted SFR-II records could allow adversaries to reconstruct the PM's security arrangements.
The original RTI application was filed in June 2018 by retired Commodore Lokesh K.
Batra seeking IAF travel details from 1 April 2013 onwards.
The court held that expenditure of public funds alone does not justify disclosure that could compromise the PM's security.
The ruling sets a precedential limit on the CIC's authority to override security agency assessments in RTI matters.
The Delhi High Court on 15 October 2026 set aside a Central Information Commission (CIC) order that had directed the Indian Air Force (IAF) to disclose details of foreign visits undertaken by Prime Ministers Narendra Modi and Manmohan Singh on IAF aircraft, holding that such disclosure could compromise national security and endanger the life and physical safety of the Prime Minister.
What the Court Ruled
A single-judge Bench of Justice Amit Mahajan, while allowing a petition filed by the Central Public Information Officer (CPIO) of the Directorate of Personal Services at Air Headquarters, ruled that the IAF was justified in denying the information under Sections 8(1)(a) and 8(1)(g) of the Right to Information (RTI) Act, 2005. The court observed that even after redacting names and identifying particulars of security personnel, the residual details could enable sensitive aspects of the Prime Minister's security arrangements to be reconstructed by correlating them with publicly available information.
'This Court or the CIC cannot sit in appeal over the subjective satisfaction of the competent security agencies as to whether disclosure of particular information could jeopardise national security or endanger the life and physical safety of the Hon'ble Prime Minister,' Justice Mahajan stated in the order.
Background: The RTI Application and CIC Order
The case originated from an RTI application filed in June 2018 by retired Commodore Lokesh K. Batra, seeking details of every foreign visit undertaken by Prime Ministers on IAF aircraft from 1 April 2013 onwards. The IAF provided certain travel details but declined to share copies of Special Flight Returns (SFR-Part II), citing exemptions under the RTI Act. It argued the records contained sensitive particulars relating to aircraft, aircrew, passengers, and Special Protection Group (SPG) personnel.
The CIC, in its order dated 8 July 2020, upheld Batra's appeal and directed the IAF to provide certified copies of the relevant SFRs. The High Court had stayed that order on 11 December 2020 while hearing the IAF's petition.
The Petitioner's Argument
Batra contended that the information pertained to expenditure of public funds on foreign visits and was therefore a matter of significant public interest. He clarified that he sought details of private persons accompanying the Prime Minister at public expense — not the identities of security personnel. The High Court, however, found this distinction insufficient to override the security exemptions.
Court's Reasoning on RTI Limits
Referring to Supreme Court precedents, Justice Mahajan underlined that the RTI Act seeks to harmonise transparency and accountability with the need to preserve confidentiality where disclosure could conflict with other public interests. The court noted that the prescribed SFR-II format contained passengers' names, designations, appointments, identification numbers, flight references, passenger strength, and agency particulars — details that are interconnected and could reveal the composition of the Prime Minister's entourage and patterns of security deployment.
'The mere fact that public funds have been expended on the foreign visits of the Hon'ble Prime Minister does not, by itself, justify disclosure of information which may compromise the security arrangements put in place for such visits,' the court held. It concluded that the CIC had erred in directing disclosure even in redacted form, and accordingly set aside the impugned order.
Broader Significance
The ruling reinforces the principle that RTI exemptions under the national security and personal safety clauses carry significant judicial deference to the assessments of competent security agencies. Notably, this is not the first time courts have had to delineate the boundary between public accountability and state security — but the explicit bar on the CIC's authority to second-guess security agencies sets a clear precedential marker. How this ruling shapes future RTI applications touching on VIP security logistics is likely to be closely watched by transparency advocates and legal practitioners alike.
Point of View
If underreported, recalibration of where RTI's accountability mandate ends and state security privilege begins. By explicitly holding that the CIC cannot sit in appellate judgment over security agencies' threat assessments, the court has effectively insulated an entire class of VIP-security-adjacent records from RTI reach — regardless of public-interest arguments. That is not unreasonable, but it does raise a harder question: if neither the CIC nor the courts will second-guess security agencies on these matters, what mechanism exists to check whether the exemption is being invoked genuinely or as a shield for embarrassing expenditure disclosures? The transparency community will push that question, and rightly so.
NationPress
19 Oct 2026
Frequently Asked Questions
What did the Delhi High Court rule on PM's foreign travel records under RTI?
The Delhi High Court set aside a CIC order that had directed the IAF to disclose details of foreign visits by Prime Ministers Narendra Modi and Manmohan Singh on IAF aircraft. The court held that such disclosure — even in redacted form — could compromise national security and endanger the PM's safety, justifying the IAF's refusal under Sections 8(1)(a) and 8(1)(g) of the RTI Act.
Who filed the original RTI application seeking IAF travel details?
Retired Commodore Lokesh K. Batra filed the RTI application in June 2018, seeking details of every foreign visit undertaken by Prime Ministers on IAF aircraft from 1 April 2013 onwards. He argued the information related to public expenditure and was in the public interest.
Why did the IAF refuse to share the Special Flight Return records?
The IAF argued that the SFR-Part II records contained sensitive particulars — including aircraft details, aircrew, passenger strength, SPG personnel data, and agency particulars — which, if disclosed alongside publicly available information, could give adversaries strategic and tactical advantages against the Prime Minister's security.
What is the significance of the Delhi HC's ruling for future RTI applications?
The ruling establishes that neither the CIC nor courts will override the subjective satisfaction of competent security agencies when they invoke national security or personal safety exemptions under the RTI Act. It sets a precedential limit on transparency-based challenges to VIP security-related records.
Does spending public funds on PM's foreign trips entitle citizens to full disclosure under RTI?
Not automatically, according to the Delhi High Court. The court held that the mere fact of public funds being expended on the Prime Minister's foreign visits does not, by itself, justify disclosure of information that could compromise security arrangements put in place for those visits.
