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

The RTI Act, 2005 was enacted to secure transparency in the working of public authorities, not to serve as a discovery tool in private adversarial litigation [1]. The Delhi High Court's order of April 28, 2026, barring disclosure of an estranged husband's income tax details, and Rajnesh v. Neha, (2021) 2 SCC 324, together confirm that maintenance law offers the fitter channel — though access-to-justice concerns temper this conclusion.

Why the RTI route is ill-suited

• Section 8(1)(j) exempts personal information where disclosure causes unwarranted invasion of privacy without larger public interest — ITR details of a private individual squarely qualify [2]. Section 8(1)(j) is the most-invoked exemption, used over 30,000 times in 2005-2010 [3].
• A spouse's maintenance claim is a private interest, not a public one; the Delhi HC accordingly set aside the CIC's July 22, 2021 disclosure order [1].
• RTI yields a document without evidentiary testing — no affidavit on oath, no cross-examination, no perjury consequence.
• Post-Puttaswamy (2017), privacy under Article 21 constrains routine disclosure of personal financial data [4].

Why the Rajnesh mechanism is superior

• It mandates that both parties file an Affidavit of Disclosure of Assets and Liabilities in all maintenance proceedings, in a uniform format issued under Articles 136 and 142 [5].
• Disclosure is court-supervised, on oath, and reciprocal, backed by three years of bank statements — wider than an ITR extract, which understates undisclosed income.
• It operates as lex specialis: a targeted remedy before the very forum deciding quantum, avoiding parallel proceedings.

Qualifications

• Efficacy depends on compliance; the Supreme Court has itself flagged that courts often fix maintenance without such affidavits on record [5].
• Economically dependent spouses still face information asymmetry, requiring judicial insistence on the affidavit and, where needed, summoning of records.

Both instruments are legitimate but differently aimed: RTI polices public power, the affidavit route resolves private financial disputes. The way forward lies in strict judicial enforcement of the Rajnesh format alongside clearer DoPT/CIC guidance on Section 8(1)(j), so that transparency and informational privacy — both constitutional values — advance together rather than at each other's cost.