Delhi HC cites national security, junks CIC order to IAF on PMs’ foreign trips

The Delhi High Court set aside a Central Information Commission order from July 8, 2020. That order had directed the Indian Air Force to provide certified copies of available and relevant Special Flight Returns, especially SFR-Part II records. The records concerned foreign visits by Indian Prime Ministers on IAF aircraft.

The court accepted the IAF’s argument that the records were sensitive. It held that disclosure could help identify security personnel, reveal the composition of a Prime Minister’s entourage, and expose patterns in security deployment. Redacting names and particulars would not necessarily remove those risks.

The decision means the CIC’s disclosure direction no longer applies. The IAF can continue withholding the requested SFR records under Section 8 of the Right to Information framework. The court said public spending on the visits alone did not justify releasing information that could compromise security arrangements.

The Central Information Commission, or CIC, is the authority involved in deciding the information dispute under India’s Right to Information system. In this case, it reviewed retired Commodore Lokesh K Batra’s complaint after the IAF refused to provide copies of certain flight records.

On July 8, 2020, the CIC directed the IAF to provide certified copies of available and relevant Special Flight Returns, specifically the SFR-Part II records. These documents related to foreign visits by Indian Prime Ministers using IAF aircraft. The IAF had already provided some information about Narendra Modi’s foreign travel.

The Delhi High Court later set aside the CIC’s direction. It found that disclosure could expose security arrangements, even if names and particulars of security personnel were removed. As a result, the CIC’s order no longer requires the IAF to release those records.

Special Flight Returns, or SFRs, are the flight records requested in this case. The article identifies two sections, SFR-Part I and SFR-Part II, but does not provide a full formal description of every field they contain. The CIC specifically ordered disclosure of available SFR-II records.

The IAF said these records could contain sensitive information. That information might enable people to identify security personnel, infer the composition of the Prime Minister’s entourage, or detect patterns in security deployment. The IAF therefore treated the records as confidential and refused to provide copies.

The High Court agreed that simply redacting names and particulars would not necessarily remove the danger. It set aside the disclosure order because remaining details could still compromise national security or a person’s physical safety. The article does not state that the records are now publicly available.

The request was broad in both leadership and time. Retired Commodore Lokesh K Batra sought information about foreign visits by Indian Prime Ministers using IAF aircraft. He asked for records from April 1, 2013, until the date of his application in 2018.

The request therefore covered Narendra Modi and former Prime Minister Manmohan Singh. The IAF provided some information about Modi’s foreign travel. It also stated that Singh had not travelled on IAF aircraft during the period from April 1, 2013, to May 25, 2014.

Batra also sought copies of the Special Flight Returns, including Part I and Part II. The IAF refused those copies, citing national security and the confidential nature of the records. The CIC later ordered disclosure of available SFR-Part II records, but the High Court overturned that direction.

The IAF’s concern was that flight records could reveal more than names. Even after names and particulars of security personnel were removed, other details might allow readers to reconstruct the security arrangements surrounding a Prime Minister’s travel.

The IAF specifically warned that the records could help identify security personnel, show the composition of the Prime Minister’s entourage, and reveal patterns in security deployment. Those clues could potentially expose how protection was organized during foreign visits. The High Court accepted that redaction would not necessarily eliminate these risks.

The court therefore treated the records as information capable of affecting national security and a person’s physical safety. It rejected the idea that removing obvious identifiers automatically made disclosure safe. The ruling means the IAF’s broader security argument prevailed over the request for certified copies.

After the High Court set aside the CIC order, the IAF is no longer required by that order to provide the requested SFR-Part II records. The court accepted that disclosure could compromise national security or the Prime Minister’s safety. This removes the specific route that had required certified copies to be released.

The IAF had refused copies of SFR-Part I and Part II because the records were sensitive and confidential. Although it provided some information about Modi’s foreign travel, it withheld the detailed returns. The court found that redacting security personnel details would not necessarily make disclosure safe.

The article does not describe any separate appeal, new disclosure process, or future release date. Based on the ruling, detailed access remains unavailable under the security exemption. The decision also confirms that public money spent on a visit does not automatically make related security records public.

India’s Right to Information system allows people to seek government records, but access is not unlimited. Section 8 of RTI exempts information whose disclosure could jeopardise national security or pose a risk to a person’s life and physical safety. The exemption protects sensitive information from being released merely because it is held by the government.

Here, the request concerned public foreign visits and spending on IAF aircraft. Yet the IAF argued that detailed records could identify security personnel, reveal the Prime Minister’s entourage, and expose security deployment patterns. The High Court agreed that redaction might not remove those risks.

The ruling shows how the law balances openness with protection. The court said public funds being spent on a visit did not by itself justify disclosure. In this case, the security exemption prevailed, so the requested detailed SFR records remained withheld.