NATIONAL SECURITY OVERRIDES DISCLOSURE: DELHI HIGH COURT SHUTS RTI ROUTE TO MODI AND MANMOHAN SINGH’S IAF FOREIGN-TRAVEL RECORDS

October 21, 2026

NEW DELHI, OCTOBER 21: The Delhi High Court has set aside an order of the Central Information Commission (CIC) directing the Indian Air Force (IAF) to disclose detailed records of foreign visits undertaken by Prime Minister Narendra Modi and former Prime Minister Manmohan Singh on IAF aircraft, ruling that disclosure could have implications for national security and the Prime Minister’s personal safety.

In an order passed on October 15, Justice Amit Mahajan held that the right to information must be balanced against the need to protect sensitive security information. The court concluded that the applicant had not established a sufficiently compelling larger public interest to justify releasing the requested records.

The case originated in an application filed under the Right to Information Act by retired Commodore Lokesh K. Batra, who sought information concerning foreign visits undertaken by Indian prime ministers on IAF aircraft between April 1, 2013, and June 5, 2018. The request included records known as Special Flight Returns, which contain details about aircraft, aircrew, passengers and the entourage accompanying the Prime Minister.

The IAF had informed the applicant that former Prime Minister Manmohan Singh had made no air travel on IAF aircraft between April 1, 2013, and May 25, 2014. It also stated that Narendra Modi had undertaken three visits on IAF aircraft between June 4, 2016, and July 9, 2018. However, the Air Force refused to provide the requested detailed flight records, citing exemptions under the RTI Act.

In July 2020, the Central Information Commission directed the IAF to provide certified copies of the available and relevant Part II Special Flight Returns. The commission’s order proposed that the names and identifying particulars of security personnel be redacted before the records were disclosed. The Air Force subsequently challenged that direction before the High Court.

The IAF argued that removing the names of security personnel would not eliminate the risks associated with disclosure. The records contained information about aircraft, aircrew, passengers, flight references, passenger strength, agencies involved and security personnel accompanying the Prime Minister. According to the Air Force, these details could be correlated with information already available publicly to reconstruct elements of security arrangements and identify patterns of deployment.

The applicant, meanwhile, argued that the records concerned expenditure on foreign visits financed through public funds and therefore involved a significant public interest. He maintained that his request was intended to establish details about private individuals who might have accompanied the Prime Minister at public expense, rather than to obtain the identities of security personnel.

The High Court rejected the argument that the use of public money, by itself, was sufficient to require disclosure. Justice Mahajan observed that expenditure from public funds did not automatically justify releasing information that could compromise security arrangements. The court also held that the Central Information Commission could not substitute its own assessment for that of the competent security agencies regarding the potential danger posed by disclosure.

The judgment upheld the IAF’s reliance on Sections 8(1)(a) and 8(1)(g) of the RTI Act, which provide exemptions relevant to information affecting national security and information that could endanger the life or physical safety of individuals. The court found that the commission had erred in ordering disclosure even after the proposed redaction of security personnel’s identifying details.

Allowing the Air Force’s petition, the High Court set aside the CIC’s disclosure order and disposed of the pending applications.

The ruling establishes that, in this case, the public-interest argument concerning expenditure on the Prime Minister’s foreign travel was insufficient to override the security concerns identified by the IAF and accepted by the court. The detailed records sought by the applicant will therefore not be disclosed under the direction issued by the Central Information Commission.

The decision brings the dispute over access to the foreign-travel records of Modi and Manmohan Singh to a close at the High Court level, underscoring the legal tension between transparency in the use of public funds and the protection of sensitive information concerning the security of the country’s highest political office.