PM’s IAF Flight Records Exempt from RTI Disclosure, Rules Delhi High Court in CPIO, Air Headquarters v. Commodore Lokesh K. Batra

Case: The Central Public Information Officer, Directorate of Personal Services, Air Headquarters, Indian Air Force v. Commodore Lokesh K. Batra (Retd.)
Citation: 2026:DHC:9404
Date of Judgment: 15 October 2026
Court: High Court of Delhi
Coram: Justice Amit Mahajan
Proceedings: W.P.(C) 10165/2020

Court Observation

“The potential implications of such disclosure for national security and the security apparatus accompanying the Hon’ble Prime Minister cannot be disregarded.”

Summary

The Delhi High Court has set aside a Central Information Commission order that had directed the Indian Air Force to disclose detailed records of Prime Ministers’ foreign travel on IAF aircraft. Justice Amit Mahajan held that Special Flight Returns — containing details of aircraft, aircrew and the entire entourage including SPG personnel — are exempt from disclosure under Sections 8(1)(a) and 8(1)(g) of the Right to Information Act, 2005, as disclosure could compromise national security and endanger the Prime Minister’s life and physical safety.

The Court ruled that neither the High Court nor the CIC can sit in appeal over the subjective satisfaction of the competent security agencies on whether disclosure would jeopardise national security, and that courts cannot substitute their own assessment for that of the agencies entrusted with the Prime Minister’s security.

Key Holdings

• Special Flight Returns (Part I and Part II) relating to the Prime Minister’s foreign travel on IAF aircraft fall within the exemptions under Sections 8(1)(a) and 8(1)(g) of the RTI Act.
• Disclosure of details such as aircraft, aircrew and SPG personnel accompanying the Prime Minister could compromise national security and endanger the Prime Minister’s life and physical safety.
• The assessment of whether disclosure would jeopardise national security falls primarily within the domain of the competent security agencies; the Court cannot substitute its own assessment for theirs.

Background

Retired Commodore Lokesh K. Batra filed an RTI application on 5 June 2018 seeking details of foreign visits undertaken by Indian Prime Ministers on IAF aircraft between April 2013 and June 2018, including Special Flight Returns. After the Air Force refused disclosure citing national security exemptions, the Central Information Commission directed disclosure of certified copies of Special Flight Returns (Part II), prompting the Air Headquarters to challenge the CIC order before the Delhi High Court.

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Disclaimer: This is a summary prepared for informational purposes only and does not constitute legal advice. Readers should refer to the official judgment for the authoritative text.