The Commonwealth Court has ruled that documents not related to a contract to perform a governmental function and not in the possession of a governmental agency are not subject to disclosure under the Right-to-Know Law merely because the agency is legally allowed to audit those records.

A three-judge panel unanimously overturned a ruling of the state Office of Open Records that directed the Office of the Budget to turn over copies of the payroll of a construction company to which it granted Redevelopment Assistance Capital Project funds.

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