Gujarat High Court: No Public Interest in Seeking PM Modi's Degree

Home / News updates PM Modi Degree | No Public Interest In Seeking PM's Degree When Qualification Has No Bearing On Election: Gujarat HC X By - Lawbeat News Desk | 30 Sept 2026 2:11 PM IST Court holds educational qualification is personal information exempt from disclosure under RTI; says public curiosity cannot be equated with public interest; upholds ₹25,000 cost imposed on Arvind Kejriwal The Gujarat High Court has held that there is "no public interest much less larger public interest" in seeking information about the educational qualification of the Prime Minister of India when such qualification has no bearing on his election to the constitutional post. A Division Bench of Chief Justice Sunita Agarwal and Justice D.N. Ray made the observation while dismissing AAP convenor Arvind Kejriwal's appeal against the March 31, 2023 judgment of a Single Judge, which had quashed a 2016 direction of the Central Information Commission (CIC) requiring Gujarat University to provide information concerning Prime Minister Narendra Modi's educational degree. The Bench also declined to interfere with the ₹25,000 cost imposed on Kejriwal by the Single Judge. The Division Bench held that educational qualification documents, including degrees and marksheets, constitute "personal information" and are also information held by universities and examining bodies in a "fiduciary capacity" . Such information is therefore protected under Sections 8(1)(j) and 8(1)(e) of the Right to Information Act, 2005 , subject to the statutory requirement of larger public interest where applicable. The Court specifically rejected the proposition that the fact that the information concerns the Prime Minister automatically brings it within the ambit of "public interest" or "larger public interest" . "No public interest much less larger public interest would require seeking of information of the educational qualification of the Prime Minister of India, who is an elected representative of the people and when his educational qualification has no bearing on his election to the Constitutional post" Court held. The Court further noted that the CIC had not recorded any reason explaining why disclosure of the information was necessary in terms of the exemptions under Section 8(1)(e) and 8(1)(j) of the RTI Act. 'Public Curiosity Cannot Be Equated With Public Interest' The Bench also considered the CIC's reasoning that there was considerable public curiosity about the Prime Minister's educational qualifications. The High Court noted that "curiosity cannot be equated with public interest" and that merely because members of the public may be interested in particular information does not mean that disclosure of that information satisfies the public-interest test under the RTI Act . The Court referred to the distinction between something being "of interest to the public" and something being "in the public interest" . It noted that the justification advanced before the Single Judge, that information concerning a candidate contesting elections should be available for public scrutiny, did not establish the requisite public interest. The Bench further observed that the mere fact that information concerning the Prime Minister's degree was already available in the public domain did not determine the question of disclosure under the RTI Act. What was relevant was whether the information fell within the statutory exemptions and whether the requirements for overriding those exemptions had been satisfied. Educational Qualification Has No Bearing On Election To PM's Post A significant part of the judgment concerned the absence of any educational qualification requirement for occupying elected constitutional offices. The Court noted that there is no prescribed educational qualification for contesting electoral positions under law. It consequently found no public-interest basis for compelling disclosure of the Prime Minister's educational qualification when the qualification itself has no bear