Tuesday, 2 December 2014

Whether Medico-Legal Certificate of co-injured can be given under RTI?


   In any eventuality, the MLC reports and 
other   records   assume   importance   in   establishing   negligence   or   otherwise,   which   will   be 

useful for claiming insurance money by the injured persons and deceased person. In this 
case all the injured persons are involved in same accident, they could be ‘accused’ and their 
negligence or innocence need to be established in the court of law.  Hence, MLC and related 
information, cannot be treated as third party information or personal information. There is 
public interest in giving such information to the appellant, who is the  father of the deceased, 
for whatever worth it is for him, in the interests of criminal justice. 
CENTRAL INFORMATION COMMISSION
(Room No.315, B­Wing, August Kranti Bhawan, Bhikaji Cama Place, New Delhi 110 066)
File No.CIC/SA/A/2014/000072

Shri Satbir Singh
Vs
Rao Tula Ram Memorial Hospital
GNCTD, Delhi

Date of decision : 25­-11-­2014
  Information Commissioner :
Prof. M. Sridhar Acharyulu
(Madabhushi Sridhar)
  Referred Sections
:
Sections 3, 19(3) of the RTI
Act



FACTS:
2.   The appellant Mr Satbir Singh is father of Anil Kumar, a young man who died in an a 
motor vehicle accident on 13.7.2013, where two motor vehicles collided in Delhi. Mr Naveen, 
Mr Vikas, Mr Monu were also injured in this accident. Appellant sought vide RTI application dt 
31.8.2013  copy of MLC dt 13.7.2013 in respect of Vikas,  Monu, Navin and Anil Kumar; No. of 
Vans attached with the Hospital and how many Ambulances were in hospital premises on 

13.7.2013; copy of registration slip of these people and their medical treatment  records.   The 
PIO Dr Sangeetha Basu has promptly written to Mr Naveen Mr Vikas and Mr Monu seeking 
permission to give information sought by appellant about MLC report etc regarding those 
persons. Mr Naveen wrote back saying he had no objection in giving MLC and other papers. 
The photocopies of MLC of Navin and Anil, son of appellant were given on 7.10.2013. The 
CPIO vide reply dt 23.8.2013 claimed the exemption of section 8(1)(j) on point 1 and 3 saying 
she did not receive any communication from Vikas and Monu. Being aggrieved by the CPIO 
reply ,the appellant made First appeal on 12.10.2013. FAA vide order dt 9.11.2013 held that 
the MLC report cannot be provided but direct the CPIO to provide other information like MLC 
no. police station etc. On non­compliance of the FAA order within the prescribed time and for 
complete information, the appellant made Second Appeal before the Commission.
Decision
3.    Both the parties made their submissions.  The respondent/PIO submitted that they had 
already provided MLC reports in two cases namely, Anil and Vikas.   The reports in other 
cases are not  provided, as the  third party  has  not replied anything  to  their  letter.    They, 
therefore, submitted that in the absence of definite response from the third party, they are not 
able   to  take   any  decision   to  provide   the   information.     Moreover,   these   cases   are   under 
investigation by the SHO, Jaffarpur PS.  
4.           Whether the information sought is the Medico Legal Case report?   Is it a public 
document or deemed to be confidential & personal? Whether accused has right to that 
information either under RTI or under any other law? The Medico Legal Case (MLC) is 
defined as “any case of injury or ailment where, the attending doctor after history taking 
and clinical examination, considers that investigations by law enforcement agencies (and 

also   superior   military   authorities)   are   warranted   to   ascertain   circumstances   and   fix 
responsibility regarding the said injury or ailment according to the law”.  
5.   Medico Legal reports are prepared by the hospital on the instruction of the Police 
authorities.   The   reports   are   used   by   the   police   to   establish   guilt   during   prosecution. 
Medico   legal   cases   include   certificates   of   Physical   Examination   of   any   person,   by   a 
Specialist Medical Officer or Team of Specialist Medical Officers, on the written requisition 
from a Judicial or Police Officer.
6.   The rule laid down in Abdul Halim Khan v. Saadat Ali Khan, AIR 1928 Oudh 155, was 
that "when a Civil Surgeon reports to a Magistrate he is merely giving his expert opinion and 
is not making a record of his 'act' in official capacity for the use of the public. It is only his act 
of making a record in such a capacity that would be considered to be an 'act' within the 
meaning of S. 74." Judges in that case explained that the opinion of the Medical Officer 
contained in the post­mortem report was only to aid the Investigating Officer in investigation. 
The report cannot be held to be a record of Medical Officer of his official "act" for the use of 
the public. It is well settled that the post­mortem report or an injury report is not substantive 
evidence. It has to be proved by the maker of it. It cannot, therefore, be termed as a public 
document as envisaged under S. 74 of the Evidence Act”. This was accepted by Delhi High 
Court  in  State  vs   Gian   Singh  decided  on  13  October,  1980,  by  A  B  Rohatgi,   Chiranjit 
Talwar, JJ. (http://www.indiankanoon.org/doc/1940919). This Bench held: As a rule, the post­
mortem report is bound to contain the opinion of the Medical Officer. He is to opine whether 
the injuries were post­mortem or ante­mortem; he is to state the approximate time of death. 
Invariably he must mention the kind of weapon which was used in causing the injuries.
7.     This Commission has ordered in file No.CIC/AD/A/2013/000778­SA dated 13/6/2014 
saying...”every medico­legal report is not a public document. Especially when related to 
prosecution of criminal charges, the disclosure of those documents depend upon several 

legal provisions. These medico­legal case records are not prepared at the instance of the 
accused or patient, but were made for the legal requirements of criminal justice system”.
8.           In  Union of India through Director, Ministry of Personnel, PG & Pension v.  
Central Information commissioner, the Delhi High Court held in Writ Petitions 8396/2009, 
16907/2006,     4788/2008, 9914/2009, 6085/2008, 7304/2007, 7930/2009 and 3607 of 2007 
on 30th November, 2009 under paragraph 87: “FIR and post mortem reports are information 
as   defined   under   Section   2(f)   of   the   RTI   Act   as   they   are   material   in   form   of   record, 
documents   or   reports   which   are   held   by   the   public   authority”.   If   disclosure   of   such 
information impedes the investigation or apprehension of offender or prosecution of offender, 
it can be denied, as held by the Delhi High Court in the above referred case.   The said 
Section does not provide blanket exemption, even if it is partial in nature and is justified. 
Delhi High Court explained that there shall be no disclosure of post mortem reports when 
investigation is in progress. Thus MLC reports can be shared when that would not impede 
the process of investigation or prosecution. 
9.      One option before the Commission is remanding case back to CPIO for fulfilling Section 
11 requirement of seeking objections from two injured persons and giving second and third 
notices to them besides giving them opportunity to go in for first and second appeals. This 
should have been considered at the First Appellate Authority level. Unfortunately, the first 
appellate authority Dr. Vijay Rai, did not apply mind and concluded on 9.11.2013 that the 
information   sought   could   not   be   provided.   As   more   than   one   year   was   lapsed,   and   the 
process would take long time for completion,  which might cause serious injury to the public 
interest in pursuing the action in criminal case and compensation case of the deceased son 
of the appellant, the Commission thinks that remanding case back to CPIO, who did not 
perform her duty completely under Section 11, would serve no purpose and defeat the ends 
of justice for which the appellant is fighting. 

10.     This case being a motor vehicle accident wherein the son of appellant died, and the 
actions are under way to secure compensation and adjudication on allegations of negligence, 
the MLC and related record would be highly relevant to the appellant­father of the deceased 
son. The denial of MLC and other medical record of two persons injured in the same accident 
who were driving motor vehicle which collided with the other, would be improper and not 
provided by the RTI Act. Whether Section 8(1)(j) exemption will apply to this demand for 
information about MLC of another person, which is regarded as personal information,  need 
to be examined. 
11.         The   letters   dated   3.9.2013   from   to   three   injured   persons   seeking   their 
objection/permission   to   provide   MLC   and   other   medico   legal   record   pertaining   to   them, 
contained a clause “in case, you fail to submit your reply in this regard within stipulated time, 
it will be presumed that you have no objection to provide the information to the applicant”. 
The time given for reply was seven days from the date of issue of the letter.   No response 
received by the date of hearing i.e., 7.11.2014. The CPIO furnished the information about two 
injured   persons   but   withheld   the   MLC   papers   about   other   two.   The   CPIO   should   have 
presumed that those two have no objection, and should have considered whether information 
sought   could   be   given  and   issued  notice   of   her   decision   to  disclose   the   information,   as 
prescribed under Section 11(2) to Section 11(4), presuming that they had no objection as 
indicated by absence of response. Mr Navin in his letter of no objection, alleged that he 
suffered injuries because of negligent driving of Mr. Anil Kumar, son of the appellant. Since 
Mr   Anil   Kumar   is   the   deceased,   the   criminal   case   against   him   cannot   continue.   As   the 
‘negligence’ or otherwise of other users of vehicle is not known, the investigating officer might 
have decided to investigate and prosecute the case.  In any eventuality, the MLC reports and 
other   records   assume   importance   in   establishing   negligence   or   otherwise,   which   will   be 

useful for claiming insurance money by the injured persons and deceased person. In this 
case all the injured persons are involved in same accident, they could be ‘accused’ and their 
negligence or innocence need to be established in the court of law.  Hence, MLC and related 
information, cannot be treated as third party information or personal information. There is 
public interest in giving such information to the appellant, who is the  father of the deceased, 
for whatever worth it is for him, in the interests of criminal justice. 
12.   The Commission, therefore, directs the respondent authority to write to the concerned 
Investigation Officer/SHO, Jaffarpur and seek the current status of the medico­legal case and 
objections, if any, against furnishing the information, with full reasoning and justification for 
those objections.  If the disclosure of this information to the appellant, impedes investigation 
in any manner, only then the information can be withheld.   If the Investigation Officer has no 
objection or does not respond within ten days from the date of CPIO’s letter to him, and if the 
PIO/Department is ready to provide the information to the appellant, then the respondent 
authority shall furnish the desired information to the appellant after the expiry of 10 days, from 
the date of writing to the investigation officer. The entire process should be completed within 
one month from the date of receipt of this order.  The appeal is disposed of. 
(M. Sridhar Acharyulu)
Information Commissioner

Print Page

No comments:

Post a Comment