The Rajnesh v. Neha judgment provides a more appropriate mechanism for financial disclosure in maintenance proceedings than the RTI framework.

Q. "The Rajnesh v. Neha judgment provides a more appropriate mechanism for financial disclosure in maintenance proceedings than the RTI framework." Analyse. (15 marks, 250-350 words)

Section 8(1)(j) of the RTI Act, 2005 exempts personal information whose disclosure serves no larger public interest [2]. The Delhi High Court's order of 28 April 2026, setting aside a Central Information Commission direction to reveal a husband's taxable income, confirms that financial disclosure in maintenance belongs before a court, not a Public Information Officer [1].

Why the RTI route is ill-fitted - Purpose mismatch: RTI promotes transparency in public authorities; a matrimonial claim is a private adversarial proceeding, not a check on the state [1]. - Nature of the information: an Income Tax Return is "personal information", and the "larger public interest" limb cannot be invoked expansively in a purely private dispute [1][2]. - Privacy: post K.S. Puttaswamy (2017), informational privacy is protected under Article 21, requiring proportionality before disclosure. - Systemic caution: Section 8(1)(j) is the most-invoked exemption — used over 30,000 times in 2005-2010, nearly 40% of all exemptions [3] — reflecting its settled role as a privacy filter.

Why Rajnesh v. Neha fits better - It mandates that both parties file an affidavit of assets, income and liabilities in all maintenance proceedings, in a uniform format prescribed under Articles 136 and 142 [4]. - Disclosure is reciprocal and evidence-backed, supported by three years of bank statements [4], curbing the wife's tendency to exaggerate need and the husband's to conceal income. - It is court-supervised, open to cross-examination and perjury consequences — safeguards the RTI process wholly lacks.

Calibration - Its worth depends on compliance; the Supreme Court had to re-circulate the guidelines to judicial officers after widespread disregard [4]. - RTI's public-interest override survives where a public servant's income genuinely engages accountability.

Thus the two operate on separate legal tracks, and the judicial affidavit is the superior instrument for inter-spousal disclosure. Strengthening its enforcement through trial-court monitoring, legal aid and time-bound disposal would secure both the dependent spouse's access to justice and the constitutional promise of privacy — reconciling transparency with dignity rather than trading one for the other.

(~325 words)

Sources: 1. High Court of Delhi — official judgments portal — order dated 28 April 2026 (Kapil Agarwal v. CPIO, Income Tax Officer) setting aside the CIC's 22 July 2021 disclosure direction; ITR held personal information; RTI distinguished from private litigation 2. The Right to Information Act, 2005 — India Code — text and scope of the Section 8(1)(j) personal-information exemption and its public-interest test 3. PRS Legislative Research, "RTI rejections" — Section 8(1)(j) invoked over 30,000 times in 2005-2010, ~40% of all exemptions 4. Rajnesh v. Neha, (2021) 2 SCC 324 — Supreme Court judgment (District Court, Bundi repository) — mandatory affidavit of assets and liabilities, three years of bank statements, uniform format; later re-circulated for non-compliance