D. A.V. College Trust and Managing Society & Ors. vs. Director of Public Instructions

In this case, the Supreme Court held that non-governmental organisations fall within the ambit of ‘public authority’ under Section 2(h) of the Right to Information Act, 2005 if they were substantially financed by the appropriate government.

• Under this section of the RTI Act, ‘public authority’ is “any authority or body or institution of self-government established or constituted by or under the Constitution and includes – any non-government organizations substantially financed directly or indirectly by funds provided by the appropriate government.”
• The court held that ‘substantial’ means a large portion which can be both, direct or indirect and it need not be a major portion or more than 50%.