In N. Saravanan v. The Chief Commissioner (W.P. (MD) No. 4336 of 2017) case, is a landmark judgment came from the Madurai Bench of the Madras High Court.
It specifically addresses whether an advocate can use the RTI Act as a tool for their legal practice. This judgment has gained renewed attention because Information Commissioner Sudha Rani Relangi recently (January 2026) cited it to dismiss a second appeal filed by an advocate.
The Core Ruling (March 15, 2017)
In this case, an advocate sought information via RTI that was directly related to a legal matter he was handling for a client. The Court dismissed his petition, establishing the following legal principles:
The "Citizen" vs. "Advocate" Distinction: The court ruled that while every citizen has the right to seek information, an advocate cannot use that right to act as a professional agent for a client.
Preventing Misuse: The court noted that if advocates were allowed to do this, the RTI Act would be "flooded" with requests from lawyers trying to bypass the standard judicial process (like the Code of Civil Procedure) to gather evidence.
Professional Promotion: The judges explicitly stated that the RTI Act's "laudable objects" should not become a tool for advocates to "promote their practice" or serve personal/professional ends.
Crucial Quote from the Order:
"As a citizen, he can personally ask for information, but not as an Advocate on behalf of his client... otherwise, every practicing advocate would invoke the provisions of the RTI Act for getting information... which situation does not advance the objects of the scheme of the RTI Act."
Recent Application: Sudha Rani Relangi's Decision (2026)
On January 12, 2026, Commissioner Sudha Rani Relangi applied this specific precedent to a case involving a dispute over a supply contract at a Jawahar Navodaya Vidyalaya in Haryana.
The Case: An advocate filed an RTI seeking documents regarding the termination of a fruits-and-vegetables supply contract. He admitted the information was for his brother (the supplier).
The Rejection: Relangi dismissed the appeal, noting that the advocate was acting as a legal representative. She pointed out that if the brother (the citizen) wanted the information, he should have filed the RTI himself.
Result: By using the N. Saravanan precedent, the CIC reinforced that lawyers cannot be the applicants for information intended for their clients' litigation.
