Authority: Supreme Court of India (Civil Appellate Jurisdiction)
Order Date: October 26, 2026
Case Overview
- Parties: The Muppathadam Service Co‑Operative Bank Ltd. (appellant) vs. State Chief Information Commissioner & others (respondents); the 4th respondent, a member of the bank, sought documents under the Right to Information Act, 2005.
- Background: The 4th respondent applied for (i) a copy of the construction agreement between the bank and a Labour Co‑operative Society and (ii) the minutes of the bank’s last General Body Meeting. The applications were rejected by the Joint Registrar (General) of Cooperative Societies, affirmed by the State Information Commissioner, and later upheld by a Division Bench of the High Court, which directed the Registrar to provide the documents.
- Legal Issues: Whether the Registrar of Cooperative Societies, as a public authority, can access documents of a private cooperative bank without a pending inquiry under Section 65 of the Kerala Co‑operative Societies Act, 1969; and the interpretation of Section 2(f) of the RTI Act and exemptions under Section 8(1).
- Arguments: The bank contended it is not a public authority; respondents argued statutory powers permit access irrespective of a pending inquiry. Counsel cited precedents including Thalappalam Service Cooperative Bank Ltd. v. State of Kerala, Central Public Information Officer v. Subhash Chandra Agarwal, and CBSE v. Aditya Bandopadhyay.
Final Outcome
- The Supreme Court upheld the Division Bench judgment, holding that the Registrar may access the requested documents without any prior satisfaction of an inquiry.
- The Registrar is directed to provide the construction agreement and the General Body Meeting minutes to the 4th respondent within two weeks of the order.
- All pending applications, if any, are rejected and the appeals are dismissed with no further relief.
Topics: Right to Information, Cooperative Banking