All India Private Educational … vs The State Of Tamil Nadu on 8 July, 2026

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    Madras High Court

    All India Private Educational … vs The State Of Tamil Nadu on 8 July, 2026

    Author: M.Dhandapani

    Bench: M.Dhandapani

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                                                                                              W.P. No.21240/2026
    
    
                                        IN THE HIGH COURT OF JUDICATURE AT MADRAS
    
                                                   Reserved on         Pronounced on
                                                   24.06.2026             08.07.2026
    
                                                               CORAM
    
                                         THE HONOURABLE MR. JUSTICE M.DHANDAPANI
    
                                                    W.P. NO.21240 OF 2026
                                                             AND
                                               W.M.P. NO. 23002 TO 23004 OF 2026
    
                         All India Private Educational
                         Institutions Association
                         Rep. By its State General Secretary
                         K.Palaniyappan
                         No.5, M.P. Avenue
                         Majestic Colony, Saligramam
                         Chennai 600 093.                                         .. Petitioner
    
                                                                 - Vs -
    
                         1. The State of Tamil Nadu
                            Rep. By the Principal Secretary to Govt.
                            School Education Department
                            Fort St. George, Chennai 600 009.
    
                         2. The Director of Private Schools
                            Tamil Nadu Private Schools Directorate
                            DPI Campus, College Road
                            Chennai 600 006.
    
                         3. The Tamil Nadu Information Commission
                            Rep. By the State Chief Information Commissioner
                            Block No.19, Government Farm House
                            Pen Bed, Nandanam, Chennai 600 035.                          .. Respondents
    
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                                                                                                    W.P. No.21240/2026
    
    
    
                                      Writ Petition filed under Article 226 of the Constitution of India praying
    
                         this Court to issue a writ of certiorarified mandamus calling for the records
    
                         pertaining to :
    
                                      i) The order dated 25.05.2026 passed by the 3 rd respondent
                                         (Tamil     Nadu      Information      Commission)     in    Case
                                         Nos.SA4827/A/2023 & SA17794/A/2023 and
                                      ii) The     consequential     impugned       communication    Proc.
                                         No.Na.Ka.No.04303/உ2/2026 dated 01.06.2026 issued by
                                         the 2nd respondent (Director of Private Schools, Tamil Nadu)
                                         being the circular issued in purported implementation of the
                                         aforesaid order of the Information Commission and upon
                                         examination of the said records quash and set aside both the
                                         aforesaid order and the said consequential circular, the same
                                         being illegal, unconstitutional without jurisdiction, void ab
                                         initio, ultra vires the Right to Information Act, 2005 and ultra
                                         vires the Constitution of India and being violative of the
                                         fundamental       rights   of   private    unaided   educational
                                         institutions guaranteed under Articles 14, 19 (1)(g) and 21 of
                                         the Constitution of India;
                                      (b) consequently, issue a direction directing the respondents,
                                         their officers, subordinates, agents and all persons acting
                                         through or under them from in any manner implementing,
                                         enforcing or giving effect to the impugned order dated
                                         25.05.2026 passed by the 3rd respondent in Case
    
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                                                                                                 W.P. No.21240/2026
    
    
                                         Nos.SA4827/A/2023     &    SA17794/A/2023      and/or     the
                                         impugned circular Proc. No.Na.Ka.No.04303/உ2/2026 dated
                                         01.06.2026 issued by the 2 nd respondent or from taking any
                                         coercive, punitive or adverse action against any private
                                         school, educational institution or education official in
                                         furtherance of or pursuant to the said impugned orders.
    
    
    
                                         For Petitioner       : Mr. E.Vijay Anand
    
                                         For Respondents      : Mr. Mr. T.Gowthaman, AAG
                                                                Assisted by Mr.V.Prabhakaran
                                                                for RR-1 & 2
                                                                Mr. C.Vigneswaran for R-3
    
                                                                   ORDER
    

    A question of seminal importance has been raised before this Court

    through the present writ petition calling upon this Court to adjudicate as to

    SPONSORED

    whether the under the provisions of the Right to Information Act, the 2 nd

    respondent has the authority to direct the private schools established in the State

    of Tamil Nadu to display the fee structure of the school conspicuously in the

    school campus on the basis of the directions issued by the 3 rd respondent, which

    is ultra vires the Constitution and also the Right to Information Act.

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    2. The sequence of events, which led to the issuance of the impugned

    order of the 3rd respondent and the consequential order and circular of the 2 nd

    respondent are, in a nutshell, captured hereunder :-

    An application u/s 6(1) of the Right to Information Act, 2005 (for short’ the

    RTI Act’) was filed before the Public Information Officer/Personal Assistant to the

    Chief Educational Officer, Coimbatore District on 26.10.2022, seeking particulars

    with regard to the fee structures/rules fixed/permissible for private matriculation

    and higher secondary schools in accordance with the guidelines issued by the

    Government.

    3. It further transpires that instead of providing the information sought

    for, the Public Information transferred the application u/s 6 (3) of the RTI Act to

    the District Education Officer (Private Schools), Coimbatore on 28.10.2022, which

    was, in turn, transferred on 26.11.2022 to all the Matriculation and Higher

    Secondary School Principals in Coimbatore, numbering more than hundred third

    party entities, which, according to the petitioner is irregular and, therefore, no

    information was provided within the statutory period of 30 days.

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    4. Against the non-furnishing of information sought for, an appeal was

    filed u/s 19 (1) on 22.11.2022, which was also not disposed and against the non-

    compliance of the statutory prescription, two second appeals u/s 19 (3) of the RTI

    Act on 11.3.2023 and 9.10.2023 on the file of the 3 rd respondent and upon

    hearing the applicant, the impugned order dated 25.5.2026 had come to be

    passed by the State Information Commission giving wide ranging directions,

    which goes far beyond the subject matter of the original application. The

    Commissioner, while ordered compensation of Rs.25,000/- against the public

    authority u/s 19 (8)(b) also issued show cause notices to the educational officials

    u/s 20 (1) for imposition of penalties of Rs.250/- per day uptoRs.25,000/- on each

    of the official, appointed the Director of Private Schools as the Public Information

    Officer in this case u/s 19 (8)(a)(ii) and directed issuance of operational orders to

    all private schools principals and further directed all private school

    managements, including CBSE and aided schools to display fee structures on their

    notice boards, websites and admission forms and further directed all the Chief

    Educational Officers of the Districts to inspect compliance of the aforesaid

    directions and submit district-wise report.

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    5. It further transpires that for the purpose of implementation of the

    aforesaid order passed by the 3rd respondent, the 2nd respondent passed the

    impugned circular dated 1.6.2026 directing all the private schools to publish the

    government fixed fee structures by 5.6.2026 and directed inspection with regard

    to compliance of the said circular by the Chief/District Educational Officers and

    directed submission compliance reports by 10.6.2026.

    6. The main grievance espoused by the petitioner through this writ

    petition is that the petitioner was neither made a party and none of the private

    educational institutions were heard before passing the order and without hearing

    the educational institutions, all the education institutions throughout the State

    were directed to comply with the directions, which is illegal, unconstitutional and

    without jurisdiction as the private educational institutions are not public

    authorities, which are amenable to the jurisdiction of the 3 rd respondent and

    further the RTI Act would not be applicable to the said institutions. Therefore,

    aggrieved by the said impugned order and circular, the present writ petition has

    been filed by the petitioner.

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    7. Learned counsel appearing for the petitioner, at the outset, assailed the

    impugned order as also the consequential impugned circular by vociferously

    submitting that the impugned order and consequential circular are illegal,

    unconstitutional, issued without jurisdiction, void ab initio and ultra vires the RTI

    Act as also the Constitution of India, as it infringes upon the rights of the private

    unaided educational institutions guaranteed under Articles 14, 19 (1)(g) and 21 of

    the Constitution.

    8. It is submitted by the learned counsel that the 3 rd respondent has no

    jurisdiction to pass any directions against the petitioner, as the private unaided

    schools are not ‘public authorities’ as defined u/s 2 (h) of the RTI Act. It is the

    further submission of the learned counsel that RTI Act imposes obligations only

    upon ‘public authorities’ as defined u/s 2 (h). In this regard, taking this court

    through Section 2 (h), it is the submission of the learned counsel that the

    definition of ‘public authorities’ only takes within its fold only bodies established

    or constituted by or under the Constitution, or any other law made by Parliament

    or by any other law made by the State Legislature or by notification issued or

    order made by the appropriate Government. Pointing to the above, it is the

    submission of the learned counsel that private unaided educational institutions

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    are established and managed by private trusts, societies and individuals without

    State funding or direct State control and they do not fall within any of the four

    criteria u/s 2 (h). Further, no notification of the appropriate Government has also

    brought the private unaided educational institutions under the ambit of RTI

    framework and, therefore, the direction of the 3 rd respondent is grossly without

    any jurisdiction.

    9. It is the further submission of the learned counsel that the Supreme

    Court in Central Board of Secondary Education – Vs – Aditya Bandhopadhyay

    (2011 (8) SCC 497) has exhaustively interpreted Section 2 (h) and had held that

    the RTI Act applies only to public authorities as defined and not to bodies not

    answering that definition and, therefore, the private unaided educational

    institutions cannot be brought within the ambit through executive instructions or

    orders passed by the 3rd respondent.

    10. It is the further submission of the learned counsel that merely because

    the educational institution is affiliated with a statutory board, it does not ipso

    facto render the said private institution to be a public authority u/s 2 (h) of the

    RTI Act as a private educational institution affiliated to the State Board or CBSE

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    remains a private entity outside the framework of RTI Act and in this regard

    reliance has been placed on the decision of the Apex Court in DAV College Trust

    & Management Society – Vs – Director of Public Instructions (2019 (9) SCC 185).

    11. It is the further submission of the learned counsel that the 3 rd

    respondent is a creature of a statute constituted u/s 15 of the RTI Act and its

    jurisdiction is circumscribed within the four corners of the RTI Act and it has no

    authority to pass orders against entities which are not ‘public authorities’ and any

    order so passed is coram non judice and is void ab initio as held by the Apex Court

    in Kiran Singh – Vs – Chaman Paswan (IR 1954 SC 340).

    12. It is the further submission of the learned counsel that without

    admitting, for the sake of argument, it is accepted that private educational

    institutions are treated as public authorities, even then, they would be entitled to

    claim exemption from disclosure u/s 8 (1)(d) and 8 (1)(j) of the RTI Act and no

    adjudication of these exemptions was conducted by the 3 rd respondent.

    13. It is the further submission of the learned counsel that the 3 rd

    respondent had exceeded its jurisdiction by passing wide legislative and

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    regulatory directions, which is beyond the scope of the RTI application. In this

    regard, it is the submission of the learned counsel that the scope of the

    application before the 3rd respondent, in the present case, related only to the said

    case and the 3rd respondent’s jurisdiction u/s 19 (3) of the RTI Act is limited only

    to adjudicating such specific case and passing direction, if at all, to provide the

    necessary details to the applicant therein and the 3 rd respondent cannot pass

    sweeping directions when the provisions of the RTI Act has not vested such

    powers on the 3rd respondent.

    14. It is the further submission of the learned counsel that the the order of

    the 3rd respondent even goes beyond the adjudicatory mandate, as it has

    appointed the Director of Private Schools as the Public Information Officer u/s 19

    (8)(a)(ii), which officer is of a different department and further the said direction

    directing the Director to issue operational standing orders to all private school

    principals across Tamil Nadu and further directing all District Chief Educational

    Officers to conduct inspections and file district-wise compliance reports and

    further directing display of fee structures at school entrances on websites and in

    admission forms is wholly without jurisdiction. It is the submission of the learned

    counsel that the said directions are in the nature of subordinate legislation, which

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    are constitutionally vested only in the Legislature and the executive and not on a

    statutory complaints body. Therefore, the said directions do not have the

    authority of law and the same cannot be enforced by the 2 nd respondent.

    15. It is the further submission of the learned counsel that the authority

    vested u/s 19 (8)(a)(ii) to appoint a person, who shall be regarded as the Public

    Information Officer (for short ‘PIO’) is a remedial measure in an individual case,

    where a public authority has failed to designate a PIO or where the designated

    PIO is unavailable or has not discharged his duties properly and the said provision

    cannot be used a mechanism to bring in an entirely different statutory authority

    as PIO in a case where the original proceedings concerned a different public

    authority, viz., the CEO’s and DEO’s and such direction is a clear usurpation of the

    jurisdiction and beyond the ambit of the provision u/s 19 (8)(a)(ii) of the RTI Act.

    16. It is the further submission of the learned counsel that the order for

    compensation u/s 19 (8)(b) and penalty proceedings u/s 20 (1) are without

    jurisdiction and vitiated as direction has been issued on the current PIO to pay

    compensation to the RTI applicant u/s 19 (8)(b) while at the same time initiating

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    show cause proceedings u/s 20 (1) against the education officials threatening

    with penalties as provided for under the RTI Act.

    17. It is the submission of the learned counsel that Section 19 (8)(b) of the

    RTI Act empowers the commission to order for compensation by the public

    authority only where any loss or other detriment is suffered by the complainant.

    Further, penalty could be imposed on the PIO u/s 20 (1) of the RTI Act only where

    the request for information is denied without sufficient and reasonable cause or

    that incorrect, incomplete and misleading information has been given knowingly.

    It is the submission of the learned counsel that the aforesaid provision

    presupposes a valid RTI application to a public authority, whereas in the present

    case, the information sought pertained to private schools, which are not public

    authorities under the RTI Act and, therefore, the sequence of RTI proceedings is

    without foundation and neither compensation nor penalty can flow from the void

    proceedings.

    18. It is the further submission of the learned counsel that the Director of

    Private Schools is a statutory authority, who derives its powers under the Tamil

    Nadu Private Schools (Regulation) Act, 2018 (for short ‘Private Schools Act’) and a

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    perusal of the same would reveal that no provision empowers the Director to

    direct the private schools to make public disclosure of their fee structure on the

    notice boards, websites and admission forms as a standing general obligation.

    19. It is the further submission of the learned counsel that the fee fixation

    mechanism under the Private Schools Act is a separate, structured quasi-judicial

    process on the orders of the Fee Fixation Committee and the obligation of a

    school to comply with such orders is distinct from an obligation to publicly

    broadcast the fee structure through multiple channels. However, the impugned

    circular casting an obligation has no statutory force under the Private Schools Act

    or under any other law, that too on the basis of an illegal order of the 3 rd

    respondent, which is without jurisdiction. Reliance in this regard is placed on the

    decision of the Supreme Court in A.L.Kalra – Vs – Project & Equipment

    Corporation (1984 (30 SCC 316).

    20. It is the further submission of the learned counsel that the impugned

    circular also pertains to CBSE affiliated schools and other centrally affiliated

    schools in addition to State recognized private schools, which is constitutionally

    impermissible, as education is in Entry 25, List III of Seventh Schedule of the

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    Concurrent Schedule. CBSE and CISCE are autonomous bodies operating under

    the authority of the Central Government with their own affiliation and by-laws

    and, therefore, schools affiliated to these bodies are governed in matters of

    internal administration by Central Regulations and the Private Schools Act, a

    State legislation, cannot override the said central legislation.

    21. It is the further submission of the learned counsel that the decision of

    the Apex Court in T.M.A. Pai Foundation – Vs – State of Karnataka (2002 (8) SCC

    481) has unanimously affirmed that the fundamental right of the private unaided

    educational institutions to establish and administer educational institutions

    under Article 19 (1)(g) and that the said right includes decision on matters

    integral to institutional functioning including fee-related decisions and could only

    be subject to reasonable regulation for the purpose of preventing exploitation.

    22. It is therefore the submission of the learned counsel that any

    restriction upon the rights of private educational institutions under Article 19 (1)

    (g) must satisfy the twin requirements under Article 19 (6); in that it should be

    imposed by law and it is a reasonable restriction in the interests of the general

    public. However, a direction through an administrative circular unsupported by

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    specific statutory authority does not constitute law within the meaning of Article

    19 (6) as it is only a law made by Parliament or State Legislature or a valid

    subordinate legislation can be said to be ‘law’ under Article 19 (6) as enunciated

    by the Apex Court in Bijoe Emmanuel – Vs – State of Kerala (1986 (3) SCC 615).

    23. It is the further submission of the learned counsel that regulation of

    school fees must be, if at all, by law and not by an executive fiat as held by the

    Apex Court in Modern School – Vs – Union of India (2004 (5) SCC 583) and,

    therefore, the impugned order and the consequential circular are neither valid

    law nor valid subordinate legislation and, therefore, the same cannot be allowed

    to survive.

    24. It is the further submission of the learned counsel that even otherwise

    the circular compelling the private schools to broadcast its fee structure through

    notice boards, publicly accessible websites and admission forms cannot be

    sustained as there is no finding of exploitation or overcharging and, therefore,

    the same cannot qualify itself as a ‘reasonable restriction’ and applying the ratio

    laid down by the Apex Court in P.A.Inamdar – Vs – State of Maharashtra (2005

    (6) SCC 537), the State may, if at all, regulate fees to prevent profiteering, but the

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    private unaided non-minority institutions retain administrative autonomy and

    intervention therefore must be proportionate through law.

    25. It is the further submission of the learned counsel that there is glaring

    violation of Article 14 as the impugned circular has been directed to apply to all

    schools indiscriminately, viz., private schools, aided, unaided, matriculation,

    CBSE, ICSE, Nursery, Primary, Higher Secondary without any differentiation

    between categories, which is beyond the jurisdiction under the RTI Act or the

    jurisdiction of the Fee Fixation Committee. The application in an omnibus

    manner makes a manifestly arbitrary classification which is in violation of Article

    14. In this regard, learned counsel placed reliance on the decision of the Apex

    Court in E.P.Royappa – Vs – State of Tamil Nadu (1974 (4) SCC 3), wherein the

    apex Court had held that arbitrariness is antithetical to equality and that any

    arbitrary State action violates Article 14.

    26. Further, it is submitted that the direction of the 3 rd respondent

    specifically singles out private schools for a public disclosure mandate that

    applies to no other category of private enterprise operating under government

    approved pricing mechanisms such a private hospitals, private utilities, etc., and

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    this differential treatment without rational basis violates Article 14 and is contra

    to the ratio laid down by the Apex Court in Shayara Bano – Vs Union of India

    (2017 (9) SCC 1).

    27. It is the further submission of the learned counsel that there is gross

    violation of principles of natural justice as the private schools, which are targeted

    under the said impugned order have not been given an opportunity of hearing,

    though they were not parties to the RTI application as the proceedings was only

    between the applicant and the authorities. The above violation is against the

    ratio laid down by the Apex Court in Maneka Gandhi – Vs – Union of India (1978

    (1) SCC 248) and State of Orissa – Vs – Dr.Binapani Dei (AIR 1967 SC 1269). As a

    consequence thereof, the circular issued by the 2 nd respondent without any

    hearing and notice to the petitioner and other private schools also strikes at the

    root of the issue and smacks of arbitrariness, unreasonableness and mala fides.

    28. It is the further submission of the learned counsel that the fee

    structure of a private school embodies sensitive financial and institutional

    information and the school has a legitimate privacy interest in protecting the

    same from indiscriminate public disclosure and compelling unrestricted public

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    disclosure of such information on notice boards, publicly accessible websites and

    admission forms without statutory authority and without any adjudication and

    opportunity violates informational privacy and clearly falls within the ratio laid

    down by the Constitution Bench in K.S.Puttaswamy (Retd.) – Vs – Union of India

    (2017 (10) SCC 1) as the triple test doctrine in relation to privacy, viz., legality,

    legitimate aim and proportionality is not satisfied in the present case and,

    therefore, the impugned order is liable to be quashed.

    29. It is the further submission of the learned counsel that the Private

    School Act provides for a statutory right of appeal against the orders of the Fee

    Fixation Committee and against the fee fixed, many of the member schools have

    preferred appeal and others are in the process of filing appeal. Imposing upon

    the private educational institutions to display the fee structure, which is the

    subject matter of appeal would cause irreparable prejudice to the school as it

    infringes upon their statutory appellate rights which otherwise would not have a

    meaningful efficacy as the appellate rights would stand diluted on account of the

    display of the fee structure.

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    30. It is the further submission of the learned counsel that the impugned

    order of the 3rd respondents directs compliance with Section 4 (1)(b) of the RTI

    Act, which requires the public authorities to maintain and publish 17 specific

    categories of information suo motu. However, the petitioner would not fall

    within the ambit of the definition of ‘public authority’ u/s 2 (h) and, therefore,

    the direction of the 3rd respondent mandating compliance to display the fee

    structure thereof is erroneous as the extent of the application of RTI Act cannot

    stand extended to the members of the petitioner, viz., the private educational

    institutions.

    31. In fine, it is the submission of the learned counsel that the private

    educational institutions cannot be held to be ‘public authorities’ under the

    provisions of the RTI Act and the provisions of the Private Schools Act also does

    not clothe any power on the authority to direct display of the fee structure of the

    school, as executive instruction of the authority will not partake the character of

    a statutory prescription and in the light of the above, the impugned order of the

    3rd respondent and the consequential circular of the 2 nd respondent will not stand

    the test of legal scrutiny and, therefore, the same requires to be struck down and

    the writ petition should be allowed.

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    32. Per contra, learned Addl. Advocate General appearing for the

    respondents, at the outset, submitted that the writ petition is not maintainable

    either in law or on facts, as the petitioner Association has not disclosed the

    particulars of its members, who are alleged to have been affected by the

    impugned proceedings and in the absence of the same, the petitioner cannot

    claim any legal injury or infraction of fundamental right and, therefore, the

    petitioner has no locus standi to maintain the writ petition. It is the further

    submission of the learned Addl. Advocate General that the proceedings, which is

    sought to be challenged by the petitioner is one passed by the 3 rd respondent to

    which the petitioner is not a party and, therefore, without establishing the legal

    injury caused, the petitioner has no locus to question the said order and,

    therefore, the writ petition deserves to be rejected.

    33. It is the further submission of the learned Addl. Advocate General that

    the impugned circular does not create any new obligation upon the private

    educational institutions, as the fee structure determined by the Tamil Nadu

    Private Schools Fee Determination Committee has already been published in the

    official website of the Committee and, therefore, the fee structure already being

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    available in the public domain, the prayer in the present writ petition itself is

    virtually infructuous.

    34. It is the further submission of the learned Addl. Advocate General that

    when the fee particulars is already publicly available in the official website of the

    Fee Determination Committee, the consequential direction to display the same in

    the notice board of the respective schools cannot be said to be one creating any

    prejudice or creating new obligations on the private educational institutions.

    35. It is the further submission of the learned Addl. Advocate General that

    no explanation has been provided by the petitioner to object to the displaying of

    the fee structure, which is already available in the website of the Fee

    Determination Committee, as it is no longer confidential and it is available in the

    public domain.

    36. It is the further submission of the learned Addl. Advocate General that

    the provisions of the Private Schools Act empowers the competent authorities to

    issue directions, instructions, circulars and orders for the welfare of the students

    and the impugned circular has been issued in exercise of the administrative and

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    supervisory powers vested in the Director of Private Schools and for ensuring

    compliance with the orders passed by the competent statutory authorities

    governing private schools. The circular neither fixes any fees nor alters the fees

    already determined by the Fee Determination Committee, but merely seeks to

    display the fee structure already fixed and approved.

    37. It is the further submission of the learned Addl. Advocate General that

    there is a direction by the Fee Determination Committee to display the fee

    particulars in the notice board of the schools, which has not been questioned by

    the private educational institutions nor was it put to challenge till date and such

    being the case, the petitioner cannot now challenge the consequential

    administrative direction issued for the implementation of the said order.

    38. It is the further submission of the learned Addl. Advocate General that

    the impugned circular was issued pursuant to and in compliance with the

    directions issued by the 3rd respondent, who is a statutory authority and the 2 nd

    respondent was bound to act appropriately on the administrative side to comply

    with the directions of the 3rd respondent and further it is submitted that the 2 nd

    respondent has not independently adjudicating the rights of the petitioner, but it

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    was only to comply with the directions of the 3 rd respondent in order to ensure

    transparency and dissemination of information which is available in the public

    domain.

    39. It is the further submission of the learned Addl. Advocate General that

    the reliance placed on Articles 14, 19 and 21 are grossly misplaced, as the fee

    structure to be displayed are not proprietary, confidential or commercially

    sensitive information and is one determined by the Fee Determination

    Committee, which has already been published in the official website and,

    therefore, the present circular is only to promote transparency, accountability

    and informed decision making by the parents and students and is only in public

    interest.

    40. It is the further submission that it is the consistent ratio of the courts

    that education is not a business and that reasonable regulatory measures are

    permissible to ensure transparency and prevent exploitation and that the

    impugned circular had been issued not only on the directions of the 3 rd

    respondent, but also as a regulatory measure as provided for u/s 17 (3) of the

    Tamil Nadu Private Schools (Regulation) Rules, 2023 (for short ‘Rules, 2023’),

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    which mandates displaying of the fee details on the notice board or the website

    of the private school one month before the commencement of every academic

    year and such obligation having been cast on the petitioner by means of the

    aforesaid Rule, the impugned order of the 3rd respondent and the consequential

    circular of the 2nd respondent cannot be put in issue as being arbitrary, illegal and

    unreasonable and, accordingly, prays for dismissal of the present petition.

    41. Learned standing counsel appearing for the 3 rd respondent, while

    sailed along with the contentions advanced on behalf of respondents 1 and 2 also

    submitted that the original complainant, who had sought information was not

    made a necessary party to the writ petition and, therefore, the writ petition

    deserves to be dismissed for non-joinder of parties.

    42. It is further submitted that no authorization has been filed along with

    the writ petition by the petitioner to show that it has been authorised by all the

    private schools to file the writ petition. It is further submitted that the 2 nd

    respondent has accepted the order of the 3 rd respondent and had acted on it and

    the writ petitioner, being bound by the provisions of the Private Schools Act and

    Rules, 2023, is bound by the directions issued by the 2 nd respondent consequent

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    upon the orders passed by the 3rd respondent, which is a statutory authority and,

    therefore, the impugned orders cannot be said to be illegal, arbitrary or

    unreasonable.

    43. It is the further submission of the learned counsel that Section 20 of

    the RTI Act vests power on the 3 rd respondent to impose penalty and award

    compensation on the public authority and the petitioner cannot question the said

    powers. It is further submitted that the 3 rd respondent is empowered to appoint

    a PIO u/s 19 (8)(a)(ii) of the RTI Act to ensure proper implementation of the

    provisions of the RTI Act and since the direction is granted only to a public

    authority, the petitioner cannot have any grievance with regard to the same.

    44. It is the further submission of the learned counsel that the 3 rd

    respondent has issued direction only to a Government servant, viz., the Director

    of Private Schools, which post is a post defined u/s 2 (g)(iii) of the Private Schools

    Act and, therefore, the Director of Private Schools would be a public authority u/s

    2 (h) (c) of the RTI Act. It is further submitted that no direction has been issued

    on any of the private schools directly and therefore the question whether a

    private school is a public authority or not does not require any examination. It is

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    the further submission that the information sought falls under exemptions u/s 8

    (1)(d) and 8 (1)(j) is completely wrong as the information which is sought is a

    publicly available information, which relates to the fees fixed by the Fee

    Determination Committee and posted in its official website. Learned counsel, for

    the contentions raised above, submits that this case deserves to be dismissed

    and prayer is made so accordingly.

    45. This Court gave its careful consideration to the submissions advanced

    by the learned counsel appearing on either side and perused the materials

    available on record, the provisions of law to which this Court’s attention was

    drawn and also the relevant decisions which were placed for the consideration of

    this Court.

    46. Though a plethora of other contentions have been raised by both the

    parties with regard to the orders passed against the private schools, however, the

    facts in the present case boils down to the following issues which fall for

    consideration in the present writ petition :-

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    i) Whether private educations institutions would fall

    within the definition of ‘public authority’ as defined

    u/s 2 (h) of the RTI Act.

    ii) Whether the impugned order passed by the 3 rd

    respondent directing enforcement of its directions

    could withstand the test under the provisions of the

    RTI Act.

    iii) Whether the consequential order passed by the 2 nd

    respondent on the basis of the impugned order passed

    by the 3rd respondent could be sustained.

    ISSUE NO.1 :

    Whether private educations institutions would fall within
    the definition of ‘public authority’ as defined u/s 2 (h) of the
    RTI Act.

    47. Before adverting to the facts of the case and applying the provisions of

    law, it would be trite to refer to the objects and reasons for which the RTI Act

    was enacted, the preamble to which reads as under :-

    An Act to provide for setting out the practical regime of
    right to information for citizens to secure access to information
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    under the control of public authorities, in order to promote
    transparency and accountability in the working of every public
    authority, the constitution of a Central Information
    Commission and State Information Commissions and for
    matters connected therewith or incidental thereto.
    WHEREAS the Constitution of India has established
    democratic Republic;

    AND WHEREAS democracy requires an informed citizenry
    and transparency of information which are vital to its
    functioning and also to contain corruption and to hold
    Governments and their instrumentalities accountable to the
    governed;

    AND WHEREAS revelation of information in actual practice
    is likely to conflict with other public interests including efficient
    operations of the Governments, optimum use of limited fiscal
    resources and the preservation of confidentiality of sensitive
    information;

    AND WHEREAS it is necessary to harmonise these
    conflicting interests while preserving the paramountcy of the
    democratic ideal;

    NOW, THEREFORE, it is expedient to provide for furnishing
    certain information to citizens who desire to have it.

    48. From the above, it would be evident that every public authority is

    required to maintain all its record duly catalogued and indexed in a manner and

    the form which facilitates the right to information and also ensure that all records

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    that are necessary to be computerized are, within a reasonable time and subject

    to availability of resources, computerized and connected through a network all

    over the country on different systems so that access to such record is facilitated.

    Public authority has also to carry out certain other functions also, as provided

    under the RTI Act.

    49. The definition of ‘public authority’ occurring u/s 2 (h) of the RTI Act

    was considered by the Apex Court in Thalappalam Ser. Co-op. Bank Ltd. & Ors. –

    Vs – State of Kerala & Ors. (2013 (16) SCC 82), wherein the Apex Court dealt with

    the bodies/entities, which would fall within the definition of public authority’ and

    in that context held thus :-

    “26. The expression “public authority” is defined Under
    Section 2(h) of the RTI Act, which reads as follows:

    2. Definitions. In this Act, unless the context
    otherwise requires:

    (h) “public authority” means any authority or body
    or institution of self-government established or
    constituted–

    (a) by or under the Constitution;

    (b) by any other law made by Parliament;

    (c) by any other law made by State Legislature;

    (d) by notification issued or order made by the
    appropriate

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    Government, and includes any–

    (i) body owned, controlled or substantially financed;

    (ii) non-Government organisation substantially
    financed, directly or indirectly by funds provided by the
    appropriate Government.

    27. Legislature, in its wisdom, while defining the expression
    “public authority” Under Section 2(h), intended to embrace
    only those categories, which are specifically included, unless
    the context of the Act otherwise requires. Section 2(h) has used
    the expressions ‘means’ and includes’. When a word is defined
    to ‘mean’ something, the definition is prima facie restrictive
    and where the word is defined to ‘include’ some other thing,
    the definition is prima facie extensive. But when both the
    expressions “means” and “includes” are used, the categories
    mentioned there would exhaust themselves.

    Meanings of the expressions ‘means’ and ‘includes’ have
    been explained by this Court in Delhi Development Authority
    v. Bhola Nath Sharma (Dead) by L.Rs. and Ors. When
    such
    expressions are used, they may afford an exhaustive
    explanation of the meaning which for the purpose of the Act,
    must invariably be attached to those words and expressions.

    28. Section 2(h) exhausts the categories mentioned
    therein. The former part of 2(h) deals with:

    (1) an authority or body or institution of self-
    government established by or under the Constitution,
    (2) an authority or body or institution of self-

    government established or constituted by any other
    law made by the Parliament,
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    (3) an authority or body or institution of self-

    government established or constituted by any other
    law made by the State legislature, and
    (4) an authority or body or institution of self-

    government established or constituted by notification
    issued or order made by the appropriate government.

    29. Societies, with which we are concerned, admittedly, do
    not fall in the above mentioned categories, because none of
    them is either a body or institution of self-government,
    established or constituted under the Constitution, by law made
    by the Parliament, by law made by the State Legislature or by
    way of a notification issued or made by the appropriate
    government. Let us now examine whether they fall in the later
    part of Section 2(h) of the Act, which embraces within its fold:

    (5) a body owned, controlled or substantially
    financed, directly or indirectly by funds provided by the
    appropriate government,
    (6) non-governmental organizations substantially
    financed directly or indirectly by funds provided by the
    appropriate government.

    30. The expression ‘Appropriate Government’ has also
    been defined Under Section 2(a) of the RTI Act, which reads as
    follows:

    2(a). “appropriate Government” means in relation
    to a public authority which is established, constituted,
    owned, controlled or substantially financed by funds
    provided directly or indirectly-

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    (i) by the Central Government or the Union territory
    administration, the Central Government;

    (ii) by the State Government, the State
    Government.

    31 . The RTI Act, therefore, deals with bodies which are
    owned, controlled or substantially financed, directly or
    indirectly, by funds provided by the appropriate government
    and also non-government organizations substantially financed,
    directly or indirectly, by funds provided by the appropriate
    government, in the event of which they may fall within the
    definition of Section 2(h)(d)(i) or (ii) respectively. As already
    pointed out, a body, institution or an organization, which is
    neither a State within the meaning of Article 12 of the
    Constitution or instrumentalities, may still answer the
    definition of public authority Under Section 2(h)(d)(i) or (ii).

    (a) Body owned by the appropriate government
    A body owned by the appropriate government clearly falls
    Under Section 2(h)(d)(i) of the Act. A body owned, means to
    have a good legal title to it having the ultimate control over
    the affairs of that body, ownership takes in its fold control,
    finance etc. Further discussion of this concept is unnecessary
    because, admittedly, the societies in question are not owned
    by the appropriate government.

    (b) Body Controlled by the Appropriate Government
    A body which is controlled by the appropriate government
    can fall under the definition of public authority Under Section
    2(h)(d)(i)
    . Let us examine the meaning of the expression
    “controlled” in the context of RTI Act and not in the context of
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    the expression “controlled” judicially interpreted while
    examining the scope of the expression “State” under Article 12
    of the Constitution or in the context of maintainability of a writ
    against a body or authority under Article 226 of the
    Constitution of India. The word “control” or “controlled” has
    not been defined in the RTI Act, and hence, we have to
    understand the scope of the expression ‘controlled’ in the
    context of the words which exist prior and subsequent i.e.
    “body owned” and “substantially financed” respectively. The
    meaning of the word “control” has come up for consideration
    in several cases before this Court in different contexts. In State
    of West Bengal and Anr. v. Nripendra Nath Bagchi
    (MANU/SC/0310/1965
    : AIR 1966 SC 447) while interpreting
    the scope of Article 235 of the Constitution of India, which
    confers control by the High Court over District Courts, this
    Court held that the word “control” includes the power to take
    disciplinary action and all other incidental or consequential
    steps to effectuate this end and made the following
    observations:

    The word ‘control’, as we have seen, was used for the first
    time in the Constitution and it is accompanied by the word
    ‘vest’ which is a strong word. It shows that the High Court is
    made the sole custodian of the control over the judiciary.
    Control, therefore, is not merely the power to arrange the day
    to day working of the court but contemplates disciplinary
    jurisdiction over the presiding Judge…. In our judgment, the
    control which is vested in the High Court is a complete control
    subject only to the power of the Governor in the matter of
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    appointment (including dismissal and removal) and posting
    and promotion of District Judges. Within the exercise of the
    control vested in the High Court, the High Court can hold
    enquiries, impose punishments other than dismissal or
    removal….

    32. The above position has been reiterated by this Court in
    Chief Justice of Andhra Pradesh and Ors. v. L.V.A. Dixitulu
    and Ors. (MANU/SC/0416/1978
    : (1979) 2 SCC) 34.
    In
    Corporation of the City of Nagpur Civil Lines, Nagpur and
    Anr. v. Ramchandra and Ors. (MANU/SC/0419/1981 : (1981)
    2 SCC 714), while interpreting the provisions of Section 59(3) of
    the City of Nagpur Corporation Act, 1948, this Court held as
    follows:

    4. It is thus now settled by this Court that the term
    “control” is of a very wide connotation and amplitude
    and includes a large variety of powers which are
    incidental or consequential to achieve the powers-
    vested in the authority concerned….

    33. The word “control” is also sometimes used synonyms
    with superintendence, management or authority to direct,
    restrict or regulate by a superior authority in exercise of its
    supervisory power. This Court in The Shamrao Vithal
    Cooperative Bank Ltd. v. Kasargode Pandhuranga Mallya
    (MANU/SC/0728/1971
    : (1972) 4 SCC 600), held that the word
    “control” does not comprehend within itself the adjudication of
    a claim made by a co-operative society against its members.

    The meaning of the word “control” has also been considered
    by this Court in State of Mysore v. Allum Karibasappa and
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    Ors. (MANU/SC/0399/1974 : (1974) 2 SCC 498), while
    interpreting Section 54 of the Mysore Cooperative Societies
    Act, 1959 and Court held that the word “control” suggests
    check, restraint or influence and intended to regulate and hold
    in check and restraint from action. The expression “control”
    again came up for consideration before this Court in Madan
    Mohan Choudhary v. State of Bihar and Ors
    .

    (MANU/SC/0105/1999 : (1999) 3 SCC 396), in the context of
    Article 235 of the Constitution and the Court held that the
    expression “control” includes disciplinary control, transfer,
    promotion, confirmation, including transfer of a District Judge
    or recall of a District Judge posted on ex-cadre post or on
    deputation or on administrative post etc. so also premature
    and compulsory retirement. Reference may also be made to
    few other judgments of this Court reported in Gauhati High
    Court and Anr. v. Kuladhar Phukan and Anr.

    (MANU/SC/0236/2002 : (2002) 4 SCC 524), State of Haryana
    v. Inder Prakash Anand HCS and Ors .

    (MANU/SC/0547/1976 : (1976) 2 SCC 977), High Court of
    Judicature for Rajasthan v. Ramesh Chand Paliwal and Anr.
    (MANU/SC/0137/1998
    : (1998) 3 SCC 72),K anhaiya Lal Omar
    v. R.K. Trivedi and Ors. (MANU/SC/0170/1985
    : (1985) 4 SCC

    628),T MA Pai Foundation and Ors. v. State of Karnataka
    (MANU/SC/0905/2002 : (2002) 8 SCC 481) , Ram Singh and
    Ors. v. Union Territory, Chandigarh and Ors.

    (MANU/SC/1154/2003 : (2004) 1 SCC 126), etc.

    34. We are of the opinion that when we test the meaning
    of expression “controlled” which figures in between the words
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    “body owned” and “substantially financed”, the control by the
    appropriate government must be a control of a substantial
    nature. The mere ‘supervision’ or ‘Regulation’ as such by a
    statute or otherwise of a body would not make that body a
    “public authority” within the meaning of Section 2(h)(d)(i) of
    the RTI Act. In other words just like a body owned or body
    substantially financed by the appropriate government, the
    control of the body by the appropriate government would also
    be substantial and not merely supervisory or regulatory.
    Powers exercised by the Registrar of Cooperative Societies and
    Ors. under the Cooperative Societies Act are only regulatory or
    supervisory in nature, which will not amount to dominating or
    interfering with the management or affairs of the society so as
    to be controlled. Management and control are statutorily
    conferred on the Management Committee or the Board of
    Directors of the Society by the respective Cooperative Societies
    Act
    and not on the authorities under the Co-operative Societies
    Act
    .

    35. We are, therefore, of the view that the word
    “controlled” used in Section 2(h)(d)(i) of the Act has to be
    understood in the context in which it has been used vis-à-vis a
    body owned or substantially financed by the appropriate
    government, that is the control of the body is of such a degree
    which amounts to substantial control over the management
    and affairs of the body.”
    (Emphasis Supplied)

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    50. The aforesaid view of the Apex Court was approved and considered

    further in the decision in DAV College Trust & Management Society & Ors. – Vs –

    Director of Public Instructions & Ors. (2019 (9) SCC 185), wherein, it was held

    thus :-

    “12. The next contention is that a public authority can only
    be an authority or body or institution which has been
    established or constituted (a) under the Constitution; (b) by
    any law of Parliament; (c) by any law of State Legislature or (d)
    by notification made by the appropriate Government. It is the
    contention of the Appellants that only those authorities,
    bodies or institutions of self-government which fall in these
    four categories can be covered under the definition of public
    authority. It is also contended that in the Thalappalam case
    (supra) the Court did not consider the effect of Clause (d) on
    the remaining portion of the definition.

    13. On the other hand, on behalf of the Respondents it is
    urged that the reading of Section 2(h) clearly shows that in
    addition to the four categories referred to in the first part,
    there is an inclusive portion which includes (i) body owned,
    controlled or substantially financed; (ii) non-Government
    organisation substantially financed, directly or indirectly by
    funds provided by the appropriate Government.

    14. The Section, no doubt, is unartistically worded and
    therefore, a duty is cast upon us to analyse the Section, find
    out its true meaning and interpret it in a manner which serves
    the purpose of the Act.

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    15. If we analyse Section 2(h) carefully it is obvious that the
    first part of Section 2(h) relates to authorities, bodies or
    institutions of self-government established or constituted (a)
    under the Constitution; (b) by any law of Parliament; (c) by any
    law of State Legislature or (d) by notification made by the
    appropriate Government. There is no dispute with regard to
    Clauses (a) to (c). As far as Clause (d) is concerned it was
    contended on behalf of the Appellants that unless a
    notification is issued notifying that an authority, body or
    institution of self-government is brought within the ambit of
    the Act, the said Act would not apply. We are not impressed
    with this argument. The notification contemplated in Clause

    (d) is a notification relating to the establishment or
    constitution of the body and has nothing to do with the Act.
    Any authority or body or institution of self-government, if
    established or constituted by a notification of the Central
    Government or a State Government, would be a public
    authority within the meaning of Clause (d) of Section 2(h) of
    the Act.

    16. We must note that after the end of Clause (d) there is a
    comma and a big gap and then the definition goes on to say
    ‘and includes any-‘ and thereafter the definition reads as:

    (i) body owned, controlled or substantially financed;

    (ii) non-Government organisation substantially
    financed, directly or indirectly by funds provided by the
    appropriate Government;

    The words ‘and includes any’, in our considered view,
    expand the definition as compared to the first part. The second
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    part of the definition is an inclusive Clause which indicates the
    intention of the Legislature to cover bodies other than those
    mentioned in Clauses (a) to (d) of Section 2(h).

    17. We have no doubt in our mind that the bodies and
    NGOs mentioned in Sub-clauses (i) and (ii) in the second part of
    the definition are in addition to the four categories mentioned
    in Clauses (a) to (d). Clauses (a) to (d) cover only those bodies
    etc., which have been established or constituted in the four
    manners prescribed therein. By adding an inclusive Clause in
    the definition, Parliament intended to add two more
    categories, the first being in Sub-clause (i), which relates to
    bodies which are owned, controlled or substantially financed
    by the appropriate Government. These can be bodies which
    may not have been constituted by or under the Constitution,
    by an Act of Parliament or State Legislature or by a
    notification. Any body which is owned, controlled or
    substantially financed by the Government, would be a public
    authority.

    18. As far as Sub-clause (ii) is concerned it deals with NGOs
    substantially financed by the appropriate Government.
    Obviously, such an NGO cannot be owned or controlled by the
    Government. Therefore, it is only the question of financing
    which is relevant.

    19. Even in the Thalappalam case (supra) in para 32 of the
    judgment, this Court held that in addition to the four
    categories there would be two more categories, (5) and (6).”
    (Emphasis Supplied)

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    51. From the ratio laid down by the Apex Court in the aforesaid decisions,

    it clearly transpires that for a entity/body to be attracted to the first part of

    Section 2 (h), the entity/body should be either an authority or body or institution

    of self-government established or constituted by any other law made by the

    Parliament or State Legislature or established or constituted by notification

    issued or order made by the appropriate Government; to attract the second part

    of the aforesaid definition, the body/entity should be owned, controlled, or

    substantially financed directly or indirectly by funds provided by the appropriate

    government or a non-governmental organization substantially financed directly

    or indirectly by the funds provided by the appropriate government.

    52. It is also clear from the aforesaid definition that mere supervision or

    regulation as such by a statute or otherwise of a body would not make the body a

    public authority within the meaning of Section 2 (h)(d)(i) of the RTI Act.

    Therefore, the said body should not only be owned or substantially financed but

    also there should exists substantial control over the said body by the appropriate

    government and not merely supervisory or regulatory in nature, which alone

    would bring the body under the ambit of ‘public authority’ as defined u/s 2 (h) of

    the RTI Act.

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    53. In the present case, it is not in dispute that the petitioner, an

    association of private educational institutions, which is before this Court, is not

    an authority or body or institution of self-government established by or under

    the Constitution or by any other law made by the Parliament or State Legislature

    and not established or constituted by notification issued or order made by the

    appropriate Government to fall under the first part of Section 2 (h); further, the

    private educational institutions also do not fall under the second part of Section 2

    (h) of the RTI Act, as the said institutions are neither directly or indirectly

    financed by the Government nor any substantial control other than supervisory

    or regulatory nature is wielded by the Government. Therefore, the petitioner

    would not fall within the ambit of Section 2 (h) of the RTI Act to be held as a

    ‘public authority’ and, thereby, amenable to the provisions of the RTI Act for

    parting with information through the orders of the 3rd and 2nd respondents.

    54. Accordingly, this Court holds that private educational institutions,

    which are not owned or substantially financed by the appropriate government

    no control is wielded by the appropriate Government over the said private

    educational institutions, the said institutions would not fall within the ambit of

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    ‘public authority’ as defined u/s 2 (h) of the RTI Act. Issue No.1 is answered in

    the above terms.

    ISSUE NOS.2 & 3 :

    Whether the impugned order passed by the 3 rd
    respondent directing enforcement of its directions could
    withstand the test under the provisions of the RTI Act.
    Whether the consequential order passed by the 2 nd
    respondent on the basis of the impugned order passed by the
    3rd respondent could be sustained.

    Since issue Nos. 2 and 3 are interconnected, they are taken up together for

    consideration.

    55. The 3rd respondent, vide the impugned order, though has issued a slew

    of directions to the educational authorities, who are public authorities under the

    Right to Information Act, however, had stepped up further and had directed the

    Chief Educational Officer, Coimbatore District, to call the Principal of all the

    Private Educational Institutions in Coimbatore District by exercising the power u/s

    18 (3)(b) of the RTI Act and conduct an enquiry, further directed providing of the

    information sought for by the complainant before the 3rd respondent.

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    56. In addition to the above, the 3rd respondent had further held as under:-

                                             “தங் கள்      அரசு அனைத்து தனியார் (மெட்ரிக்)
                                         பள்ளிகள் ,     CBSE     மற்றும்    அரசு      உதவி     பெறும்
                                         பள்ளிகளின்            முதல் வர்களுக்கும்        பள்ளிகளில்
                                         நிர்ணயித்த கல் வி கட்டணத்தினை (Fee Structure)
                                         பொது       மக்கள்       பள்ளிகளின்         நுழைவுவாயிலில்
                                         கேட்காமலேயே.             பொதுமக்களின்           பார்வைக்கு
                                         பள்ளியின்         விளம் பரப்      பலகையில்       விளம் பரம்
                                         செய் தும் ,             அனைத்து                 பள்ளிகளின்
                                         இணையதளங் களில்                  வெளியிடவும்           மற்றும்
                                         மாணவர்களின்             சேர்க்கைக்கு       முன் னர்   மற்றும்
                                         சேர்க்கையின்          போது      தரப்படும்      விண் ணப்பப்
                                         படிவத்திலே               வகுப்புவாரியாக               கல் விக்
                                         கட்டணத்தினை அச்சடித்து வழங் குவதை அனைத்து
    

    தனியார் (மெட்ரிக்) பள்ளிகள் , CBSE மற்றும் அரசு
    உதவி பெறும் பள்ளிகளுக்கும் கட்டாயமாக்கி.

    அவ் வாறு தமிழ்நாட்டில் உள்ள ஒவ் வொரு தனியார்
    மற்றும் அரசு நிதி பெறும் மெட்ரிக் மற்றும் CBSE
    பள்ளிகளின் விளம் பரப் பலகைகளில் தங் களுடைய
    கல் வி கட்டணத்தை வெளிப்படைத் தன் மையுடன்
    விளம் பரப்படுத்துகிறதா என் பதை உறுதி
    செய் யதகவல் பெறும் உரிமைச் சட்டம் , 2005 பிரிவு
    4(1)(b) என் ற பிரிவின் படி அனைத்து மாவட்ட
    முதன் மை கல் வி அலுவலர்களுக்கு உத்தரவிட்டு.

    மேற்படி மாவட்ட முதன் மை கல் வி அலுவலர்ககள்
    அனைத்து தனியார் (மெட்ரிக்) பள்ளிகள் , CBSE

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    மற்றும் அரசு உதவி பெறும் பள்ளிகளை ஆய் வு
    செய் து மேற்படி கல் வி கட்டணம் தொடர்பான
    தகவல் கள் பொதுமக்கள் அறியும் வகையில்
    விளம் பரம் செய் யப்பட்டுள்ளதா என் பதை உறுதி
    செய் து மாவட்ட வாரியான அறிக்கையின்
    நகலினைப் பெற்று இவ் வாணையத்தில் 15.06.2026
    அன் று நேரில் ஆஜராகி சமர்ப்பிக்குமாறு
    இவ் வழக்கின் தற்போதைய பொதுத் தகவல்
    அலுவலராக நியமிக்கப்பட்ட முனைவர்.S. சுகன் யா,
    இயக்குநர் (தனியார் பள்ளிகள் ), பள்ளிக் கல் வித்
    துறை, சென் னை அவர்களுக்கு இவ் வாணையம்
    உத்தரவிடுகிறது.”

    57. Through the aforesaid direction, the 3 rd respondent, invoking Section

    19 (8)(a)(ii) of the RTI Act, had directed the 2 nd respondent to issue directions to

    the Principal of all the private, matriculation, CBSE and aided schools to display

    the fee structure fixed by the Fee Determination Committee at the entrance of

    the school and also to display the same in the website of the respective schools

    for the benefit of the general public, more especially parents of the children, who

    are studying and are in the look out for schools, even without their seeking the

    necessary information. Further, direction has also been given that while

    admission forms are provided, the schools shall provide the fee structure as an

    annexure to the admission form for the benefit of the parents. The 3 rd

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    respondent has further directed the respective District Educational Officers to

    ensure compliance of the aforesaid directions issued by the 3 rd respondent with

    regard to display of the fee structure and the Chief Educational Officers of the

    respective Districts were directed to inspect as to whether the directions

    aforesaid have been complied with and the fee structures were displayed and file

    compliance report before the 3rd respondent.

    58. The moot question that requires to be considered and tested is

    whether such sweeping directions relying upon Section 4 (1)(b) and 19 (8)(a)(ii) of

    the RTI Act could be passed by the 3 rd respondent. For better understanding,

    Section 4 (1)(b) of the RTI Act are quoted hereunder :-

    “4. Obligations of public authorities :-

    (1) Every public authority shall
    ……………

    (b) publish within one hundred and twenty days from the
    enactment of this Act,—

    (i) the particulars of its organisation, functions and duties;

    (ii) the powers and duties of its officers and employees;

    (iii) the procedure followed in the decision making process,
    including channels of supervision and accountability;

    (iv) the norms set by it for the discharge of its functions;

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    (v) the rules, regulations, instructions, manuals and
    records, held by it or under its control or used by its employees
    for discharging its functions;

    (vi) a statement of the categories of documents that are
    held by it or under its control;

    (vii) the particulars of any arrangement that exists for
    consultation with, or representation by, the members of the
    public in relation to the formulation of its policy or
    implementation thereof;

    (viii) a statement of the boards, councils, committees and
    other bodies consisting of two or more persons constituted as
    its part or for the purpose of its advice, and as to whether
    meetings of those boards, councils, committees and other
    bodies are open to the public, or the minutes of such meetings
    are accessible for public;

    (ix) a directory of its officers and employees;

    (x) the monthly remuneration received by each of its
    officers and employees, including the system of compensation
    as provided in its regulations;

    (xi) the budget allocated to each of its agency, indicating
    the particulars of all plans, proposed expenditures and reports
    on disbursements made;

    (xii) the manner of execution of subsidy programmes,
    including the amounts allocated and the details of
    beneficiaries of such programmes;

    (xiii) particulars of recipients of concessions, permits or
    authorisations granted by it;

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    (xiv) details in respect of the information, available to or
    held by it, reduced in an electronic form;

    (xv) the particulars of facilities available to citizens for
    obtaining information, including the working hours of a library
    or reading room, if maintained for public use;

    (xvi) the names, designations and other particulars of the
    Public Information Officers;

    (xvii) such other information as may be prescribed; and
    thereafter update these publications every year;

    c) publish all relevant facts while formulating important
    policies or announcing the decisions which affect public;

    d) provide reasons for its administrative or quasi-judicial
    decisions to affected persons.”

    59. Section 4 (1) is very clear, in that, it is only the public authorities, as

    defined u/s 2 (h) of the RTI Act, are alone mandated to comply with the aforesaid

    conditions stipulated u/s 4 (1) (b) and through an administrative caveat, the same

    cannot be extended to private educations institutions, which, by no stretch, could

    be said to be a public authority, as has already been held by this Court and,

    therefore, such a direction of a sweeping nature cannot be given u/s 4 (1)(b) of

    the RTI Act.

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    60. Likewise u/s 19 (8)(a)(ii) of the RTI Act, power has been granted to the

    Central Information Commission/State Information Commission to appoint

    Central Public Information Officer or State Public Information Officer as the case

    may be. There could be no quarrel with the said power of the 3 rd respondent.

    However, it has to be exercised in exceptional cases and only where a case

    warrants such invocation. In the present case, information, which was sought for

    by the complainant was not provided, which necessitated the 3 rd respondent to

    appoint the Director of Private Schools as the State Public Information Officer for

    the purpose of providing the said information. Such an exercise of power is well

    within the domain of the 3rd respondent and the same could not be found fault

    with and, therefore, to that extent the said order does not suffer any infirmity.

    61. Though there could be no explicit direction by the 3 rd respondent

    through the 2nd respondent to the private educational institutions to provide the

    information to the parties, who seek information under the RTI Act, however, it is

    not as if the act of the 3rd respondent to provide the information or rather to

    keep the parents of the students informed of the fee structure is not backed by

    any statute.

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    62. The private schools are governed by the Private Schools Act and the

    Rules framed thereunder. Chapter II of the Private Schools Act deals with the

    power to regulate school education while Chapter VI deals with control of private

    school. Section 32 of the Private Schools Act speaks of fees and other charges,

    which is as under :-

    “32. Fees and other charges :- (1) Subject to the provisions
    of sub-section (2), no private school shall levy any fee or collect
    any other charge or receive any other payment except a fee,
    charge or payment specified by the competent authority.
    (2) Every private school in existence on the date of the
    commencement of this Act and levying different rates of fees
    or other charges or receiving any other amount on such date,
    shall obtain the prior approval of the competent authority
    before continuing to levy such fees or charges or receive such
    payment.”

    63. Sub-section (2) of Section 32 of the Private Schools Act clearly specifies

    the manner in which fees or charges have to levied by the different private

    schools and before such levy is made, approval of the competent authority is to

    be obtained. Therefore, the fees or other charges, prior to the coming into

    existence of the Fee Determination Committee, was approved by the competent

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    authority and the said fees was very much within the knowledge of the

    competent authority.

    64. Since there was varying fees collected by the various private schools,

    the Tamil Nadu Schools (Regulation of Collection of Fee) Act, 2009 (Act 22 of

    2009) was enacted to provide for a structured fee fixation for any standard or

    course of study in a private school. Section 3 (2) of Act 22 of 2009 prescribes as

    under :-

    “Prohibition of collection of excess fee :-

    ……………………

    (2) No fee in excess of the fee determined by the
    committee under this Act shall be collected for admission of
    pupils to any Standard or course of study in a private school,-

    (a) by any person who is in charge of, or is responsible for,
    the management of such private school; or

    (b) by any other person either for himself or on behalf of
    such private school or on behalf of the management of such
    private school.

    (3) The fee collected by any school affiliated to the Central
    Board of Secondary Education shall commensurate with the
    facilities provided by the school.”

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    65. Therefore, no private school is to collect any fee in excess of what is

    determined by the Committee under Act 22 of 2009. Further, the powers and

    functions of the committee is provided for u/s 7 and sub-section (2) therein, it

    mandates that each private school to place before the committee the proposed

    fee structure of such school with all relevant documents and books of accounts for

    scrutiny within such date as may be specified by the committee” if any complaint

    is raised with regard to levy of fee other than what is fixed by the committee.

    66. It is the specific case of the 2 nd respondent that the fees fixed for the

    private schools by the Fee Determination Committee is hosted in the website of

    the committee. Therefore, what is fixed and what is to be charged by each and

    every private school is already available in the website of the committee and no

    private school is permitted to collect any fee over and above what has been

    determined and fixed by the Committee.

    67. The Private Schools Act is a piece of legislation enacted to regulate and

    monitor the acts of the private schools. Section 57 of the Private Schools Act

    confers power on the Government to make Rules. In exercise of powers

    conferred u/s 57 of the Private Schools Act, the Tamil Nadu Private Schools

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    (Regulation) Rules, 2023 (for short ‘the Rules’) have been framed. Rule 17 of the

    Rules relates to Regulation of Admission. Sub-rule (3) of Rule 17 provides every

    private school to host certain details spelt for under the said rule in the website

    and notice board and for better appreciation, the same is quoted hereunder :-

    “17. Regulation of Admission :-

    ………….

    (3) Every private school shall display on the notice board or
    host on the website, the details of the infrastructure available,
    staff strength, pupils strength, seats available for each
    standard-medium-wise including seats for children belonging
    to disadvantaged group and weaker section as required under
    clause (c) of sub-section (1) of Section 12 of the Central Act 35
    of 2009, fees fixed and other facilities available if any. The
    details so displayed shall be updated on the notice board and
    on the website by the private school one month before the
    commencement of every academic year.”

    68. Rule 17 (3) mandates every school to display on the notice board or

    host on the website, the details of the infrastructure available, staff strength,

    pupils strength, seats available for each standard-medium-wise including seats

    for children belonging to disadvantaged group and weaker section as required

    under clause (c) of sub-section (1) of Section 12 of the Central Act 35 of 2009,

    fees fixed and other facilities available if any and that the same shall be updated

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    on the notice board and on the website by the private school one month before

    the commencement of every academic year. By the said rule, the private schools

    have been mandated to display the fees fixed both on the notice board and on

    the website one month before the commencement of every academic year.

    69. When a mandate is cast on the private schools to display the fees fixed

    both on the notice board and on the website, the private schools cannot abdicate

    its responsibility and try to wriggle out of its commitment to the society that its is

    not a public authority and, therefore, information as to fees cannot be directed

    to be displayed by the 2 nd respondent. When the private schools are bound by

    the Rules, necessarily it is the duty of the competent authority to see to it that

    the mandate cast under the Rules are adhered to in letter and spirit.

    70. Further, as already stated above, the fees fixed by the Fee

    Determination Committee is published in the website of the committee and that

    the private schools cannot charge any fees beyond what has been fixed by the

    Fee Determination Committee. Such being the case, the fixation of fees already

    being displayed in the website of the Fee Determination Committee, the display

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    of the fee structure in the notice board and website of the school cannot be said

    to be beyond the jurisdiction of the 2nd respondent.

    71. In the backdrop of the aforestated scenario, this Court having already

    held that the private educational institutions, which are neither substantially

    financed nor controlled by the State/Central Government will not fall within the

    ambit of ‘public authority’ as defined u/s 2 (h) of the RTI Act, the direction of the

    3rd respondent calling upon the 2nd respondent to take action to have the fee

    structure displayed at the entrance of the schools would be an act beyond the

    jurisdiction of the 3rd respondent, as the 3rd respondent cannot give any direction

    of such a nature to the private educational institutions to display the fee

    structure at the entrance of the schools. Therefore, the direction of the 3 rd

    respondent through the impugned order resulting in the issuance of the

    impugned circular by the 2 nd respondent would not stand the test of legal

    scrutiny.

    72. Nevertheless, it is to be pointed out that even if the said direction is

    beyond the competence of the 3 rd respondent, the regulation of all the activities

    relating to private educational institutions being within the regulatory

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    mechanism devised under the Private Schools Act, it becomes incumbent on the

    private schools, which is neither substantially financed nor controlled by the

    Central/State Government, to display the fee structure as mandated u/s 17 (3) of

    the Rules, as the fee is not only determined by the Fee Determination

    Committee, but is also displayed in the website of the Committee and is already

    available in the public domain.

    73. Further, not only the fees determined by the Fee Determination

    Committee, but also all other fees, which are levied by the private schools on its

    students are to be tabled before the competent authority and approval of the

    said fees to be obtained u/s 32 of the Private Schools Act. Such being the case,

    the competent authority under the Private Schools Act would very much be

    within the knowledge of the fees, which is leviable on a student by a private

    school, as certain portion of the fees is determined and certain portion of the

    fees is approved before the same is levied.

    74. In such a backdrop, though the 3 rd respondent may have passed the

    order beyond its jurisdiction, nevertheless, when Rule 17 (3) provides for the

    display of the fee structure in the notice board and website of the private

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    schools, which is to be followed by the private schools and monitored by the 2 nd

    respondent, the circular issued by the 2 nd respondent cannot be said to be

    impermissible, merely because it is on the basis of the directions issued by the 3 rd

    respondent, as the 2nd respondent, independent of the said impugned order,

    draws power from Rule 17 (3) to mandate the display of the fee structure in the

    notice board and website in accordance with the provisions of the Private Schools

    Act. Therefore, the said circular being very much within the statutory framework

    of the Rules and the 2nd respondent holding the regulatory and supervisory

    jurisdiction is bound to ensure that Rule 17 (3) is followed by the private schools

    in letter and spirit.

    75. However, it should not be lost sight of that the parents, who want to

    admit their kids in the school of a good choice in order to secure their future

    should also be provided with the details as to the fees payable so as to enable

    them decide on admitting their kids in the said school, as their purse should not

    burn which would have a detrimental effect on the household. Only with a view

    to allow the parents to decide effectively and plan the future of their child,

    Rule17 (3) of the Rules plays a pivotal role in such decision making process. Rule

    17 (3) is a benevolent provision not only in regulating and supervising the

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    activities of the private schools, but also helps the parents in deciding the further

    course of action for their kids to get standardised education without burning

    their pockets. Therefore, as already held above, the display of fees being within

    the statutory framework, which stems from Section 17 (3) of the Rules, a duty is

    cast on the private schools to display the fees in the notice board and the website

    of the concerned schools and the regulation of the same is within the jurisdiction

    of the 2nd respondent, necessarily the 2 nd respondent is bound to monitor as to

    whether Rule 17 (3) is complied with.

    76. Therefore, the aforesaid direction of the 3 rd respondent would not act

    as an embargo for the 2nd respondent to issue the circular. However,

    notwithstanding the same, there would be no embargo for this Court to pass

    orders directing display of the fee structure while sitting under Article 226 of the

    Constitution, as this Court is clothed with extraordinary powers to see that the

    statutory mandate made under the Rules is complied.

    77. Therefore, as mandated u/r 17 (3), this Court, exercising its

    extraordinary jurisdiction under Article 226 of the Constitution directs the private

    schools to display the fee structure fixed by the Fee Determination Committee as

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    also the other fees, which have been approved by the competent authority in

    terms of Section 32 of the Private Schools Act in the notice board and website of

    the respective private schools and the same shall be updated by the private

    schools one month before the commencement of every academic year. Issue

    Nos. 2 and 3 are answered in the aforesaid terms.

    78. It is further to be noted that for non-compliance of the provisions of

    the RTI Act, the 3rd respondent has invoked its power u/s 20 to levy penalty on

    the authorities while also ordering payment of compensation to the complainant.

    Section 20 of the RTI Act, which gives power to the 3 rd respondent to impose

    penalty clearly stipulates that where the Central Public Information Officer or the

    State Public Information Officer has, without any reasonable cause refused to

    receive an application for information or has not furnished information within the

    time specified under sub-section (1) of Section 7 or malafidely denied the request

    for information or knowingly given incorrect, incomplete or misleading

    information or destroyed information which was the subject of the request or

    obstructed in any manner in furnishing the information, shall be levied with

    penalty.

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    79. In the present case, the details sought for with regard to the fee

    structure was not available with the 2 nd respondent or the authorities under the

    2nd respondent, but was only available with the private schools. Though Rule 17

    (3) stipulates display of the fee structure, however, it is not clear whether the

    private schools were complying with the mandate. In the absence of compliance,

    the 2nd respondent would not be in possession of the information and the only

    manner in which the said information would be available is through Rule 17 (3).

    When such information is not available with the 2 nd respondent or its officials,

    mulcting the officials of the 2nd respondent by holding that they have not

    provided the information sought for by the complainant is arbitrary and unjust.

    Further, except for saying that the information has not been provided, the 3 rd

    respondent has not stated how the penalty stands attracted, as the infraction for

    attracting the penalty has not been explicitly stated. Though no separate petition

    has been filed by the 2nd respondent or the officials of the 2nd respondent,

    however, the same would not stand in the way of the court setting aside the said

    portion of the direction also, as the petitioner has, through this present petition,

    espoused the cause of the officials as well and this Court, exercising its

    extraordinary powers, could correct the wrong that has been caused. Therefore,

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    this Court holds that the penalty imposed by the 3 rd respondent on the officials of

    the 2nd respondents cannot be sustained and the same deserves to be set aside.

    80. In fine, this writ petition is disposed of in the following terms :-

    i) The portion of the impugned order passed by the 3 rd

    respondent imposing penalty on the officials of the 2 nd

    respondent and ordering compensation to the

    complainant is set aside.

    ii) The order of the 3rd respondent directing the 2nd

    respondent to ensure display of fee structure at the

    entrance of the school and report compliance thereof is

    modified and this Court, invoking its extraordinary

    jurisdiction under Article 226 of the Constitution directs

    the 2nd respondent to ensure display of fee structure on

    the notice board and website of the respective school by

    invoking its regulatory power u/r 17 (3) by all the private

    schools as spelt out in the preceding para Nos.71 to 79

    and, therefore, the private schools coming within the

    aegis of the petitioner as also the other private schools

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    which are recognised under the Private Schools Act are

    directed to display the fee fixed by the Fee Determination

    Committee as also the other fees, which have been

    approved by the competent authority in terms of Section

    32 of the Private Schools Act in the notice board and

    website of the respective private schools and the same

    shall be updated by the private schools one month before

    the commencement of every academic year.

    Consequently, connected miscellaneous petitions are closed. There shall

    be no order as to costs.

    
    
    
    
                                                                                             08.07.2026
                         Index         : Yes / No
                         GLN
    
    
    
    
                         61
    
    
    
    
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                         To
    
                         1. The Principal Secretary to Govt.
                            School Education Department
                            Government of Tamil Nadu
                            Fort St. George, Chennai 600 009.
    
                         2. The Director of Private Schools
                            Tamil Nadu Private Schools Directorate
                            DPI Campus, College Road
                            Chennai 600 006.
    
                         3. The State Chief Information Commissioner
                            Tamil Nadu Information Commission
                            Block No.19, Government Farm House
                            Pen Bed, Nandanam, Chennai 600 035.
    
    
    
    
                         62
    
    
    
    
    https://www.mhc.tn.gov.in/judis
                                                         ____________
                                                   W.P. No.21240/2026
    
    
    
                                             M.DHANDAPANI, J.
    
                                                          GLN
    
    
    
    
                                      PRE-DELIVERY ORDER IN
                                      W.P. NO. 21240 OF 2026
    
    
    
    
                                          Pronounced on
                                            08.07.2026
    
    
    
                         63
    
    
    
    
    https://www.mhc.tn.gov.in/judis
    



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