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26 MUTfICIPAL RECORDS § 14•14 <br />parent has a common-law right to inspect school records relating to <br />his son -5 <br />Books, accounts, papers, and documents which are public -records <br />are at all tunes open to inspection of interested citiens and tapay- <br />ers,fi subject, ofcourse, to reasonable rales and regulations in regard <br />to the time and manner of such examination, with a view to the <br />safety of such records and the proper use of then by the public <br />officials! Every officer, appointed by lava to keep records is merely <br />in that relation a trusted of such records for the public who have an <br />interest in the inspection of them." Charters and statutes provide for <br />the inspection of all books, accounts, and papers ofmunicipal corpo- <br />rations or of those of any municipal department, or bureau thereof,' <br />and prescribe that, in case of refusal, the court may, on proper <br />application, by rule compel inspection.10 It has been said that the <br />purpose of such provisions is to prevent corruption and mismanage- <br />ment in city government, and that the underlying theory is that <br />publicity is a preventative or cure for such evils.' <br />On the other hand, the right to inspect public documents and <br />records at common law is not absolute. There may be situations <br />where the harm done to the public interest may outweigh the right <br />of a member of the public to have access to particular documents or <br />records; thus, the one must. be balanced against the other in deter- <br />mining whether to permit the inspection. 12 Inspection may be de- <br />i - <br />nied when public policy demands that certain records in the custody <br />of public officials be kept secret, 13 a+g., police and law department <br />records,"' and where public health or safety is concerned."' It has <br />been declared, however, that contracts, bids, employment recons, <br />etc., are not such documents or records the exposure of which would <br />be' dangerous to the public interest or detrimental to its welfare." <br />It has also been held that where access to the payroll records of <br />a city police department was sought by a newspaper and reporter, <br />disclosure would be granted where the records world not, In them- <br />selves, operate to the prejudice or impairment of a person's reputa- <br />tion or personal security." The possibility that the records, if used <br />in conjunction vA th other information, might prejudice and impair <br />the policemen's reputations did not exempt them from disclosure- x a <br />Further, it has been held that disclosure of the payroll records of a <br />city's policemen does not constitute an infringement of the officers' <br />' <br />constitutionally guarded zone ofprivacy."' <br />There is no right of inspection when it is sought to satisfy a per- <br />son's mere whim or fancy, to engage in pastime, -to create scandal, <br />to degrade another, to injure public morals, or to further any im- <br />proper or useless purpose. Under some statutes there must be a <br />III <br />