Court says even anonymised medical data cannot be disclosed under RTI if it violates Article 21 privacy rights
Mumbai: The Bombay High Court has quashed an order passed by the State Information Commission that had directed the Public Information Officer of Goa Medical College to disclose details of ICU patients under the Right to Information (RTI) Act.
Court Emphasises Patient Privacy Over RTI Disclosure
The High Court ruled that sharing medical information of patients admitted to ICU Ward 123—even without revealing their identities—would violate the Right to Privacy guaranteed under Article 21 of the Constitution.
The court made it clear that anonymised data is also protected if it can potentially infringe upon an individual’s privacy, setting a significant precedent on the limits of RTI in sensitive healthcare matters.
Background: Father Sought ICU Data After Son’s Death
The case arose after a man, D’Mello, sought details of 21 patients admitted to the ICU on January 25 and 26, 2024, following the death of his son in a road accident.
He had approached authorities claiming that his son was denied an ICU bed despite being in a more critical condition than some of the admitted patients. His intention was to compare the severity of medical conditions to establish possible negligence.
In February 2025, the State Information Commission directed the hospital to provide the requested data—excluding personal identifiers.
Court: Personal Grief Cannot Override Privacy Rights
Justice Neela Gokhale acknowledged the father’s grief but held that the request did not meet the threshold of larger public interest required for such disclosures.
The court observed that while the father’s intent was not malicious, seeking details about other patients’ medical conditions was “not appropriate” and could not be justified under the RTI framework.
Landmark Observation on RTI and Medical Confidentiality
The ruling reinforces that medical records are highly sensitive personal data, and their disclosure—even in anonymised form—must pass strict privacy safeguards.
It further highlights that the Right to Privacy takes precedence over RTI when it comes to confidential health information.
Implications for Future RTI Requests
This judgment is expected to have wider implications on RTI applications involving healthcare institutions, ensuring that patient confidentiality remains protected while balancing transparency in public administration.
The verdict sets a clear boundary, stating that individual grievances, however genuine, cannot justify access to third-party medical records.
