Allowing a writ petition in Registrar of Companies & Ors v Dharmendra Kumar Garg & Anr, Delhi High Court held that the provisions of the Right to Information (RTI) Act, 2005, would not override the provision in the Companies Act, 1956, for accessing information that is in the public domain.
The court ruled that as the RTI Act is a general statute and the Companies Act is a special statute and an earlier piece of legislation, “the later general law cannot be read or understood to have abrogated the earlier special law”.
The Registrars of Companies (ROCs) of Delhi and Haryana had appealed a decision by the Chief Information Commissioner (CIC), directing them to provide information to Dharmendra Kumar Garg that was (a) available in the public domain under the Companies Act and (b) not held by or under a public authority.
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