CIC Dismisses Multiple RTI Appeals: Curbing Repetitive Litigation Under RTI Act, 2005 - 2025-09-24

The Endless Loop: CIC Closes Door on Massive Multi-Appeal RTI Barrage

In a sweeping move to preserve the integrity of the Right to Information (RTI) Act, 2005, the Central Information Commission (CIC) has dismissed a vast series of second appeals filed by Satish Ashok Sherkhane against the Security Printing & Minting Corporation of India (SPMCIL) and its various units. Commissioner Anandi Ramalingam, presiding over a batch of interconnected appeals, characterized the appellant’s conduct as a "never-ending stream of questions" designed to harass the public authority.

A History of Legal Friction

The cases at hand are not isolated incidents but rather the latest chapter in a long-standing dispute between the appellant and SPMCIL, following his dismissal from service. According to previous Commission orders highlighted in the decision, Sherkhane has filed over 300 RTI applications, many identified by earlier benches as "frivolous and vexatious." Despite repeated caution by the Commission to refrain from using the RTI Act to redress personal grievances and to exercise judicious use of the law, the appellant persisted, filing numerous fresh appeals that echoed previously adjudicated matters.

The Core of the Dispute

The appellant sought broad, often vaguely defined, photocopies of "all file notings," "Action Taken Reports," and "documents prepared or executed" regarding various administrative processes—notably caste verification and disciplinary proceedings. Public Information Officers (PIOs) across several SPMCIL units—from Mumbai and Kolkata to Nashik and Noida—consistently resisted these requests, citing exemptions under Section 8(1)(j) for personal third-party information and Section 8(1)(e) concerning fiduciary duties. Some offices also noted that the sheer scale of the requests threatened to divert "meagre resources" from the department's core public functions.

Judicial Reasoning: The Principle of Finality

Relying on the precedent established in Mr. Ramesh Chand Jain Vs. DTC (CIC, 2014), the Commission reaffirmed the doctrine of "constructive res judicata" within the RTI framework. The principle dictates that an applicant must seek all relevant information in a single, comprehensive opportunity.

"He cannot file another application for a bit or piece which he forgot to ask, or not advised by his lawyer, or for any other reason," the CIC noted, echoing the principle that the RTI Act is not a tool for unending harassment.

Key Observations

The Commission’s patience with the appellant was clearly exhausted. In its order, the Bench observed: * "The Commission... observes that the Appellant is a cantankerous, disgruntled employee who is trying to harass the public authority by filing numerous RTI application asking for all and sundry information." * "The above-listed appeals are therefore dismissed without going into the merits as they are considered multiple and vexatious with a focus on harassing the public authority." * "The Appellant is reminded that filing the same request with the CPIO by a mere inter play of words will not change the narrative of the case which has been already decided by the Commission."

Final Decision: A Summary Dismissal

Observing that the appellant continued to file futile applications immediately following a strict 2024 advisory, the CIC summarily dismissed all pending appeals in the current batch. The order serves as a stern reminder that the RTI Act, while powerful, is not an instrument for perpetual litigation and the exhaustion of administrative resources. The Commission has finally declared these matters closed, advising all parties to treat this as a definitive stance on the appellant's repetitive filings across all SPMCIL units.