Right to Information

        

For BCAJ December, 2007

 Narayan Varma

CIC’s decisions :

Disclosure of cabinet papers

The first proviso to S. 8(1)(i) of the RTI Act reads as under :

“Provided that the decision of the Council of Ministers, the reasons thereof, and the material on the basis of which the decisions were taken shall be made public after the decision has been taken, and the matter is complete, or over.”

Smt. Aruna Roy and Shri Shekhar Singh, very senior RTI activists, made an RTI application to the Ministry of Personnel, Public Grievances and Pensions, Department of Personnel and Training (DOPT) requesting for disclosure of papers concerning amendment to the RTI Act. The same was rejected under the above proviso, holding that the “matter is not complete or over” yet. It was the contention of the applicants that “matter is complete or over” as the decision has already been arrived at and that it has already been notified through press.

To make the decision on this controversial matter, the CIC called for the relevant records from DOPT on 5-11-2007 in a sealed cover. The Commission perused the records and returned the same. The following were the findings :

“We find that the note for the Cabinet was submitted on 15-7-2006, which contained suggestions for amendment to the RTI Act, 2005. This Cabinet note sought approval of the Cabinet for moving amendments (Para 13). A tentative amendment Bill was suggested at para 14. This note was approved by the Cabinet on 20-7-2006. Subsequently, a notice of intention to  resent the Bill was submitted to the Rajya Sabha by Minister of State Shri Suresh Pachouri on 28-7-2006. No such notice could be seen on the file addressed to the Lok Sabha. The Cabinet Secretary through a letter of 10-10-2006 to the Secretary DoPT sought a copy of the Bill introduced in the Parliament. By a letter of 19-10-2006, DoPT informed the Cabinet  Secretary that the Bill had not been introduced.”

Based on the above facts, the Commission held :

It is accepted that a decision on a Cabinet note cannot be treated as complete, unless the matter of the decision has been completed, which in this case would mean moving an amendment to the RTI Act, 2005 as per the Cabinet decision. Till such

amendment is actually moved or a decision taken, that no such amendment will be moved, the matter cannot be treated as complete or over.

The decision of the First Appellate Authority, Dy. Secretary to Govt. of India, DoPT rejecting the appeal petition by his order dated 13th October 2006, under proviso to Clause (i) of Ss.(1) to S. 8 of the Right to Information Act, 2005 is, therefore, upheld.

[Smt. Aruna Roy and Shri Shekhar Singh v. DoPT, New Delhi, Adjunct to Appeal No. CIC/WB/A/ 2006/01022, dated 12-11-2007]

Investigation papers at CBI Anti-Corruption Unit

One Shri Hari Ram Naik sought certain information from CBI which had registered a case against him. He was denied the information, PIO holding that the disclosure of information/documents sought is likely to endanger the life or physical safety of  he persons who have provided such information in confidence and further it would impede the process of prosecution which is in progress in a Court of law. The Appellate Authority also rejected the appeal on three grounds :

1. Disclosure of information could identify the source of information or assistance given in confidence for law enforcement — S. 8(1)(g)

2. The matter being under trial, the disclosure could impede the prosecution — S. 8(1)(h)

3. The information sought has no relationship to any public interest — S. 8(1)(j)

The Commission held :

“Of the above, although points 1 & 2 have weight, point 3 is entirely misplaced. The prosecution is obviously being conducted by the CBI in the public interest and it cannot, therefore, be argued that the documents concerned with this prosecution are not in the public interest or part of a public activity. On the other hand, as admitted by the appellant Shri Hari Ram Malik, the documents he has sought from the Court have been provided to him, although the actual release of the documents has been delayed.”

However, the Commission finally held that “The Commission cannot act as enforcement agency of a judicial authority. It advised the appellant to make an application to the appropriate Court for copies of any documents that he may require to assist in his defence. The Court may at its discretion take a sympathetic view in this matter because of the personal tragedies suffered by the appellant.

The appeal was dismissed.

[Shri Hari Ram Malik v. CBI Appeal No. CIC/WB/A/2007/00002, dated 25-10-2007]

Disciplinary case before ICAI

On 24-10-2007, the Commission heard the appellant Shri Mukesh A. Shah and the representative of ICAI. The appellant had asked for huge information under 32 items relating to a disciplinary case, which has already been disposed of by the Court. The CPIO has responded and informed him that the documents on the basis of which the charges were relied upon were already furnished. The appellant has however mentioned that the information sought are somewhat different from those already supplied to him in the disciplinary case.

During the hearing, the CPIO requested for an opportunity to re-examine the application which was agreeable to the appellant. Accordingly, a decision was given as under :

As agreed between the parties, the CPIO is directed to review and examine the application for information afresh. And, accordingly furnish a point-wise response as per the provision of the Act. In case, any information is to be denied, the grounds for doing so should be clearly mentioned for review by the Commission, if necessary. The CPIO is accordingly directed to dispose of the matter within three weeks’ period from the date of issue of this decision.

[Shri Mukesh R. Shah v. The ICAI, Decision No.1351/IC(A)/2007 F. No. CIC/AT/A/2007/00816 of 25th October, 2007]

Dispute re. allotment of bank audit

The appellant is one Mr. Vijay Kumar Khanna of Kanpur and the public authority is the Institute of Chartered Accountants of India. The matter was heard on 24-10-2007. The following is the full copy of the decision.

Facts :

The appellant has sought information under the RTI Act by his letter dated 15-7-2006 addressed to CPIO, The Institute of Chartered Accountants of India, New Delhi in the following manner :

(i) Provide a copy of the Constitution Certificate of the firm as on 1st January 2005.

(ii) Provide a copy of the CD sent (containing the details of information about firms for the purposes of allotment of Bank audit) or if sent in any other mode, the copy of the same in which the information of the firm as on 1-1-2005 was sent to C&AG office for the purpose of allotment/finalisation of panel for allotment of bank audit prepared on the basis of data of the firm sent as on 1-1-2005 for the purpose of allotment of Bank audit for the year ended 31-3-2006.

(iii) Provide a copy of any correspondence sent to the Office of the Comptroller and Auditor General of India responsible for sending the names of firms eligible for appointment as Central Statutory Auditor of a bank/Part C auditors.

(iv) Provide the action taken by Institute on his grievance application dated 18-3-2006 with reference No. CA/MISC/31/PTA/2205-2006/Vol.37/Encl. dated 18-3-2006 addressed to the Reserve Bank of India, Cuffe Parade, Mumbai and sent through the Chairman, Professional Development Committee of the Institute of Chartered Accountants of India, Indraprastha Marg, New Delhi–110002.

The CPIO furnished his reply vide his letter dated 14-8-2006, by which he has refused to furnish the copy of the CD, since it is pertaining to information of other firms. He has also said that there was no correspondence entered into with the C&AG in connection with the appointment of Central Auditor of a Bank. Dissatisfied with the reply furnished by the CPIO, the appellant filed his first appeal before the AA. The AA reiterated the same stand taken by the CPIO while giving his reply on 13-8-2006.

Aggrieved, the appellant filed present appeal before the Commission on 6-12-2006.

2. Comments were called for from public authority, vide letter dated 16-3-2007, which was received on 30-3-2007. The appellant has not submitted his rejoinder.

Decision :

3. This case came up for hearing on 24-10-2007, which was attended by the CPIO in person as well as AA and the appellant. The appellant is not satisfied with the reply furnished by the CPIO or the AA. He has specifically requested for a copy of the CD sent by the Institute of Chartered Accountants of India to the C&AG office for the purpose of allotment and finalisation of panel. During the hearing, the CPIO has shown a copy of certificate, wherein the particulars of his firm are shown, which was sent to him. According to the appellant, this information is available in respect of all the firms in public domain and it is not the same which they have sent to the C&AG office for drawing the panel. His grievance is that he has been shown as a partner in his firm, whereas he apprehends that while forwarding the CD, his name has not been included in the list as partner in respect of the firm. In order to satisfy himself, he wanted to get the copy of the CD that was sent to the C&AG in respect of his firm only, which will indicate whether his name has been included in the list or not. The CPIO has been directed to provide this CD, by excluding the information of other firms under the provisions of S. 10(1) of RTI Act, and

provide the CD to the appellant within 15 days from the date of receipt of this direction. On the above lines, the appeal is disposed of.

[Appeal No. 1046/ICPB/2007 F. No. PBA/07/255 of October 30, 2007]

The RTI Act

Reporting on the judgment of the High Court of Gujarat (the Court) — continuing from November issue.

The second issue decided by the Court is whether the PIO should pass speaking order when he discloses information relating to or supplied by a third party and what satisfaction must be arrived at prior to such information treated as confidential by that third party is disclosed.

It was the contention of Shri Mardia and the Gujarat SIC that no reasons are required to be assigned u/s.7(1) of the Act, 2005, for passing an order for grant of information. This contention is not accepted by this Court, mainly for the reason that if the information supplied is pertaining to third party, reasons for imparting such information to the applicant ought to be given, otherwise the Appellate Authority cannot know the mind of the Public Information Officer. An appeal is provided u/s.19(2) of the Act, 2005. Third party can prefer an appeal. Reasons reveal the mind of the Lower Authority. Reasons of an order is like soul of an order, without it, the same must be declared ineffective. If the reasons are not given for disclosure of the information relating to third party or supplied by third party, the order can be known as non-speaking order. In the facts of the present case, the orders passed by the respondent authorities are totally non-speaking orders and, hence, deserve to be quashed and set aside.

Shri Mardia’s counsel contended that the PIO’s act is administrative in nature and relied on some Supreme Court’s decisions. However, the Court relied on the Supreme Court’s decision in the case of Indian National Congress v. Institute of Social Welfare and others, reported in AIR 2002 SC 2158, especially in para-24, as under :

“The legal principles laying down when an act of a statutory authority would be a quasi-judicial act, which emerge from the aforestated decisions are these :

Where (a) a statutory authority is empowered under a statute to do any act (b) which would prejudicially affect the subject (c) although there is no lis or two contending parties and the contest is between the authority and the subject, and (d) the statutory authority is required to act judicially under the statute, the decision of the said authority is quasi-judicial.”

In view of the aforesaid decision also, the Public Information Officer is a quasi-judicial authority as he is empowered under the statute i.e., the Act, 2005 to do an act (disclosing of information), which would affect prejudicially a third party. Third party can prefer an appeal u/s.19(2) of the Act, 2005. Therefore, such authority has to pass a reasoned order.

On the point of satisfaction to be arrived at prior to disclosure of information about third party, the Court held that the Act imposes a duty upon the Public Information Officer to arrive at a conclusion that public interest in disclosure outweighs the harm or injury to the protected interest of such third party, or larger public interest warrants disclosure of such information.

The Court relied on the decision rendered by the Supreme Court in the case of Ashok Kumar Pandey v. State of West Bengal and others, reported in AIR 2004 SC 280, especially in paras 12 and 14. Extracts from the said two paras :

12. The attractive brand name of public interest litigation should not be used for suspicious products of mischief.

14. The Court has to be satisfied about (a) the credentials of the applicant (b) the prima facie correctness or nature of information given by him. The Court has to act ruthlessly while dealing with imposters and busybodies or meddlesome interlopers impersonating as public-spirited holy men. They masquerade as crusaders of justice. They pretend to act in the name of Pro Bono Publico, though they have no interest of the public or even their own to protect.

The aforesaid factors will be considered by the Public Information Officer before disclosing the information relating to or supplied by a third party and has been treated as confidential by that third party.

In conclusion, the Court held that in the facts of the present case, no conclusion has been arrived at by the concerned respondent authorities, and, hence, the orders passed by the concerned respondent authorities deserve to be quashed and set aside.

Other News

Mumbai Police Budget :

The information provided in response to an RTI application reveals that the Mumbai Police spent more than 85% of its money just to pay salaries to its workforce of 40,000. Thus, only small amount of funds are available for modernisation and intelligence gathering.

RTI Act and transparency :

One of the objectives of the RTI Act is to boost transparency. It got a boost in the decision of the CIC Bench of two members when it held that Government departments would have to come clean when they give sensitive assignments to employees despite a question mark over their integrity. Whenever violation of the ‘agreed list’ containing names of employees kept under the gaze of the Central Bureau of Investigation and internal vigilance on account of doubtful integrity of employees is noticed and officers figuring on the list were appointed to sensitive assignments, the names both of the officers taking those decisions and of the officers figuring on the list and benefiting from the action of the appointing authority, would be disclosed.

Navi Mumbai Police Commissionerate :

It is surprising that Navi Mumbai Police Commissionerate has not heard a single RTI appeal till date and has summarily dismissed 74 appeals without hearing a single case. The State Information Commissioner has summoned the Commissioner, Mr. Ramrao Wagh for an explanation on receiving this information on a complaint from a Vashi resident.

Judicial accountability :

Issues of judicial accountability and extending right to information laws to the Judiciary have once again come to the fore in the wake of certain allegations against former Chief Justice of India (CJI) Y. K. Sabharwal. On September 21, the Delhi High Court moved against three Mid Day journalists for reporting about the former CJI.

Judges invoke the right to know when they find their own interests in jeopardy. But why should the same right not be invoked when people demand information or accountability from the Judiciary ? Judges generally take the plea that the functioning of the Judiciary is transparent, as proceedings take place in the open Court and every judgment is a public document which is subject to criticism. However, after the passage of the RTI Act in 2005, decisions of other functionaries too have come under greater scrutiny than before. Little is known about the administrative actions of the Judiciary.

Most High Courts have not even appointed Public Information Officers (PIOs) as required under the RTI Act. Those which have appointed PIOs have framed their own rules which clearly prohibit the disclosure of information on administrative matters

relating to expenditure on Judges and procedures followed in appointments of class-III and IV employees of the High Court This amounts to a violation of the Act as exemptions from disclosures are permissible only on certain grounds specified u/s.8 of the Act. The High Court rules have arbitrarily enhanced the application fees from the nominal Rs.10 to even Rs.500. Penalty for non-disclosure has been reduced from Rs.25,000 to a meager Rs.500 which can hardly act as a deterrent. The SC must realise that rights cannot be withdrawn once given. Whether it is the Justice Sabharwal controversy or functioning of the Judiciary at large, greater transparency is called for. (Extracts from The Times of India of 24-9-2007 : Article by Sudhanshu Ranjan)

RTI Act review :

Two years after it came into force, the Government has decided to conduct a detailed evaluation of the Right to Information (RTI) Act which, it says, has won ‘immense’ public response.

The Personnel Ministry project, to be provided technical support by the London-based consultancy Adam Smith International (ASI) and Administrative Staff College of India (ASCI), has also been promised a grant by the British Government’s Department for International Development (DFID). The one-year study will be conducted by a firm or consultant to be selected through a process.

The ambitious review will not only evaluate how the RTI Act has worked at different levels from the Central Government down to the panchayats, but also identify the main problem areas and actionable steps for making it more effective. The law, passed on June 21, 2005, still has serious zones of conflict with the Official Secrets Act, although it is supposed to prevail in case of a dispute.