Sanjiv Chaturvedi vs CBI Compliance Report Sought in RTI Contempt Case

Parijat Tripathi

Sanjiv Chaturvedi vs CBI: Delhi High Court Seeks Compliance Report in RTI Contempt Case

A long-running legal dispute between Uttarakhand-cadre Indian Forest Service (IFS) officer Sanjiv Chaturvedi and the Central Bureau of Investigation (CBI) over disclosure of investigation-related records under the Right to Information (RTI) Act continues to remain before the Delhi High Court. The latest development came after the court directed the CBI to place a compliance report on record in connection with contempt petitions filed by Chaturvedi.

Justice Mini Pushkarna passed the direction on September 2, asking the central investigating agency to submit its compliance report before the next hearing, which is scheduled for February 3, 2027. The direction, however, has been made subject to any interim or final order that may be passed by a division bench of the High Court, where the CBI is challenging the earlier single-judge judgment at the centre of the dispute.

How the Dispute Between Sanjiv Chaturvedi and CBI Began

The present proceedings have their roots in information sought by Chaturvedi under the RTI Act relating to CBI investigations into alleged corruption and irregularities at the All India Institute of Medical Sciences (AIIMS), New Delhi.

Chaturvedi had served as Chief Vigilance Officer (CVO) at AIIMS and, during his tenure, had referred a number of matters involving alleged irregularities to the CBI for investigation. The subsequent RTI proceedings revolved around his demand for access to records and internal documents connected with those investigations.

At the heart of the controversy is a December 2019 order of the Central Information Commission (CIC). The commission had directed the CBI to provide Chaturvedi with internal file notings and other records relating to the investigations. The agency resisted the disclosure, relying on the exemptions available to it under the RTI Act.

The matter eventually moved to the Delhi High Court after the CBI challenged the CIC’s decision.

Delhi High Court Rejects Blanket CBI Exemption

A significant turning point came in January 2024, when a single-judge bench of the Delhi High Court dismissed the CBI’s challenge to the CIC order. The court upheld the direction relating to disclosure of information sought by Chaturvedi.

The judgment also dealt with an important question concerning Section 24 of the RTI Act. The CBI is included in the Second Schedule of the legislation and is therefore generally exempt from the obligation to disclose information under the RTI framework, subject to the statutory exceptions.

The High Court made it clear that this position does not amount to an unrestricted or blanket exemption. Information relating to allegations of corruption and human rights violations can come within the proviso to Section 24, although the law also recognises that sensitive information connected with certain investigations may continue to attract protection.

The case before the court concerned information sought by Chaturvedi about CBI investigations into alleged corruption, including matters related to procurement and other administrative issues at AIIMS.

The CBI subsequently challenged the January 2024 single-judge decision before a division bench of the Delhi High Court. That challenge remains pending and has become an important part of the continuing legal battle.

Contempt Proceedings Follow Alleged Non-Compliance

After the single-judge judgment, Chaturvedi approached the High Court with contempt proceedings, alleging that the directions concerning disclosure had not been properly complied with by the CBI.

In March 2024, the court issued notice to the CBI’s Central Public Information Officer (CPIO) in connection with the contempt plea. Chaturvedi’s contention was that documents and information which, according to him, had been directed to be supplied under the court’s order had still not been furnished.

The contempt proceedings have also brought former CBI officials Vineet Vinayak and Gagandeep Gambhir, an IPS officer of the 2004 Gujarat cadre, into the picture. Earlier, in September 2023, the Delhi High Court had issued contempt notices to the two officers in connection with allegations of non-compliance with an earlier order concerning information sought from the CBI.

The proceedings therefore span several stages of litigation and relate to the larger question of how information ordered to be disclosed under the RTI framework is to be dealt with while the concerned agency continues to pursue legal remedies against that disclosure order.

CBI Calls Contempt Plea an Attempt to ‘Arm-Twist’ Agency

The CBI has strongly contested the contempt proceedings and has maintained that it has been pursuing remedies available to it in law.

In an affidavit filed before the Delhi High Court in April 2024, the agency’s Anti-Corruption Branch opposed the contempt proceedings initiated by Chaturvedi. The CBI alleged that the contempt petition was an attempt to “arm-twist” the agency and interfere with its ability to pursue the legal options available to it.

The affidavit was filed in the wake of contempt notices issued after Chaturvedi alleged that the CBI had failed to comply with the January 30, 2024 order of the High Court.

The agency’s position was that its challenge to the earlier judgment was still pending before the division bench. It argued that contempt proceedings should not effectively prevent the CBI from exercising its right to challenge the single-judge decision through the appropriate judicial process.

These arguments represent the CBI’s position in the litigation and should not be read as a finding by the court against Chaturvedi.

Latest Delhi High Court Direction

The latest order keeps the compliance question alive while the CBI’s substantive challenge remains pending before the division bench.

The agency had informed the court that its challenge to the single-judge judgment was pending and was listed before the division bench for October 7, 2026. Justice Mini Pushkarna nevertheless directed the CBI to file a compliance report before the next hearing in February 2027.

At the same time, the single judge made it clear that the direction would remain subject to any interim or final order that the division bench may pass in the CBI’s pending challenge.

That qualification is significant because the litigation is now moving on two connected tracks. The contempt proceedings concern alleged non-compliance with the earlier directions, while the CBI’s appeal before the division bench continues to question the underlying order relating to disclosure.

The next stages of the proceedings could therefore depend on what the division bench decides in the pending challenge.

Who Is IFS Officer Sanjiv Chaturvedi?

Sanjiv Chaturvedi is a 2002-batch Indian Forest Service officer of the Uttarakhand cadre. He studied Electrical Engineering at Motilal Nehru National Institute of Technology (MNNIT), Allahabad, and entered the Indian Forest Service through the Union Public Service Commission (UPSC) examination.

He initially served in the Haryana cadre before being transferred to Uttarakhand. His career has included several assignments involving vigilance, administration and environmental governance, but his tenure as Chief Vigilance Officer at AIIMS brought him considerable attention because of his work on cases involving alleged corruption and administrative irregularities.

Chaturvedi’s vigilance-related work has also received national and international recognition. He was awarded the S. R. Jindal Prize in 2011, while in 2015 he received the Ramon Magsaysay Award for Emergent Leadership.

The Ramon Magsaysay Award Foundation recognised him for his integrity, courage and persistence in pursuing alleged corruption in public institutions and for his efforts to improve government systems.

RTI, Institutional Accountability and a Continuing Court Battle

The continuing dispute between Chaturvedi and the CBI illustrates the complicated intersection between transparency law, investigative confidentiality and judicial oversight. While the RTI Act provides broad rights of access to information, agencies covered by Section 24 operate under a special statutory framework, with specific exceptions relating to corruption and human rights violations.

The Delhi High Court’s earlier ruling is therefore important beyond the immediate dispute because it addressed the extent to which inclusion of an agency in the Second Schedule can shield information from disclosure. The subsequent contempt proceedings have shifted attention to another practical question – whether an order directing disclosure has actually been complied with while an appeal against that order remains pending.

For now, the matter remains unresolved on both fronts. The CBI’s challenge before the division bench is still pending, while the single-judge bench has sought a compliance report in the contempt proceedings. The next significant developments are expected from the division bench hearing as well as the February 2027 proceedings before Justice Mini Pushkarna.

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