CIC Dismisses Multiple Vexatious RTI Appeals Against SPMCIL, Citing Harassment and Constructive Res Judicata

The Never-Ending Stream: Commission Halts Repetitive RTI Filings

In a stern rebuke against the misuse of transparency provisions, the Central Information Commission (CIC) has dismissed a massive batch of second appeals filed by an ex-employee against the Security Printing & Minting Corporation of India (SPMCIL). Commissioner Anandi Ramalingam, presiding over the case, underscored that the right to information cannot be weaponized into an instrument of harassment against public authorities.

A History of Litigation

The appellant, Satish Ashok Sherkhane, a former employee of the India Government Mint (IGM) Mumbai, has been embroiled in prolonged disputes following his dismissal from service. Over the past several years, the appellant has bombarded the SPMCIL and its various units—including the India Government Mint (Kolkata, Mumbai, Hyderabad, Noida), Bank Note Press (Dewas), and Currency Note Press (Nashik)—with hundreds of RTI applications.

Seeking Vindication Through Transparency

The appellant's queries, while ostensibly seeking public interest information, largely revolved around his personal service grievances, departmental inquiries, and caste verification processes. Despite receiving responses from the Central Public Information Officers (CPIOs) and subsequent First Appeals (FAA), the appellant consistently alleged that the information provided was "fabricated" or "incomplete," leading to this latest deluge of over 40 Second Appeals heard collectively by the Commission.

The Commission’s Legal Scrutiny

During the hearing, the Commission observed that these new filings were essentially an "extension of a bunch of cases" previously decided. The CIC pointed out that the appellant’s behavior had been noted in prior judgments, describing him as a "cantankerous, disgruntled employee" using the RTI Act to settle personal scores rather than seeking genuine transparency.

The Respondent authorities collectively argued that the information sought was either voluminous, pertained to the personal medical/caste records of third-party employees—thereby triggering Section 8(1)(j) of the RTI Act—or was non-existent.

The Doctrine of Constructive Res Judicata

Invoking the spirit of Ramesh Chand Jain vs. DTC , the Commission applied the principle of "constructive res judicata." Commissioner Anandi Ramalingam noted: > "He cannot file another application for a bit or piece which he forgot to ask... It is in the public interest and also to further the objective of Right to Information Act, that such repeated or unending stream of questions... be stopped."

Key Observations

The Commission’s decision left no ambiguity regarding the appellant's intent: * "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 once again advised to refrain from misusing the RTI Act to redress his personal grievances."

Final Verdict: A Shut Door

The CIC summarily dismissed the latest collection of appeals, refusing to entertain further arguments. The Commission made it clear that while transparency is a cornerstone of democracy, the RTI Act was never intended to serve as a tool for unending, repetitive litigation designed to deplete the resources of public institutions. This ruling serves as a significant precedent for authorities facing similar patterns of "serial RTI filing" by individuals seeking to re-litigate settled service matters.