the degree and passing details cannot be treated as private or third party information

Subhash Chandra Tyagi v. CBSE

“”…..Once a student passes an examination and qualifies to secure a degree, the degree and passing details cannot be treated as private or third party information. Passing an examination is a qualification and awarding the degree such as 10th Class, 12th Class or Intermediate, graduation or postgraduation, is a public document generated by a public institution. The academic institutions awarding such degrees under a statutory authority are discharging their statutory duties such as registering the qualification details and degree related information.

10. When there is an apprehension or doubt about validity or existence of a qualification, it is necessary to verify genuineness of the same. If verification proves that it is a genuine degree, it vindicates the qualification of the candidate. If it is proved to be a wrong degree, it will serve a larger public interest. Hence the degree or academic qualification related information need to be accessible to the citizen….

11. An educated person cannot hide his education. He will necessarily incorporate his academic qualifications, as his achievements and if he secures any gold medal or rank, he will definitely display that in his biodata papers. Education being a qualification concerning the society in general, can never be treated as personal information. If someone chooses not to disclose his educational qualifications, it could be his personal choice, but if he uses those qualifications for achieving an employment or higher education or a position, that becomes public information.

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14. How can a graduate consider his degree as private and personal information, and why it should be considered as someone’s personal data. There is no basis for such understanding. If BA degree is a requirement for studying MA, the student who wants to study MA has to prove that he graduated. If he does not have that qualifying degree and manipulates to secure admission MA, every genuine graduate has a right to doubt the admission and to demand the disclosure of graduation details. For higher education or employment, he has to reveal his details of education details. If a candidate wants to treat the patients as doctor he has to prove medical graduation. Every person has a right to know genuineness of his degree or education.

Hence, all the qualifying examinations and degrees are public information and every member of public shall have access to it.
The right to information was available in its rudimentary form in Section 76 of Indian Evidence Act, 1875:

Section 76 says: Every public officer having the custody of a public document, which any person has a right to inspect, shall give that person on demand a copy of it on payment of the legal fees therefore, together with a certificate written at the foot of such copy that it is a true copy of such document or part thereof, as the case may be, and such certificate shall be dated and subscribed by such officer with his name and his official title, and shall be sealed, whenever such officer is authorized by law to make use of a seal; and such copies so certified shall be called certified copies.

Section 74 of Evidence Act, gave list of "public documents": "(1) The following documents are public documents: (i) of the sovereign authority, (ii) of official bodies and tribunals, and (iii) of public officers, legislative, judicial and executive, of any part of India or of the Commonwealth, or of a foreign country; (2) public records kept in India or private documents."

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CIC/SA/A/2016/001451 decided on 21 July 2016