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Supreme Court of India 2019-09-17 dismissed

D.A.V. COLLEGE TRUST AND MANAGING SOCIETY vs DIRECTOR OF PUBLIC INSTRUCTIONS

Bench: 2 — Deepak Gupta, Aniruddha Bose

In Brief

This case determines whether non-governmental organisations (NGOs) substantially financed by Government are "public authorities" subject to the Right to Information Act, 2005. The Supreme Court held that Section 2(h) defines six categories of public authority. While the first four require Government establishment/constitution, the definition's inclusive clause also covers any body substantially financed by Government and any NGO substantially financed by Government. "Substantial" financing does not mean majority (>50%) but rather material, considerable importance, assessed on case facts. The Court dismissed the appeal regarding D.A.V. Colleges in Chandigarh (finding them substantially financed by grants covering 40-44% of expenditure plus 95% of teaching staff costs) and remitted other similar cases to the High Court for fresh determination of substantial financing under these principles."

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Right to Information Public Authority Statutory Interpretation Non-Governmental Organisations Educational Institutions

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