Curbing the RTI Menace: Commission Clamps Down on Repetitive Appeals Against SPMCIL

In a decisive move to protect public resources and prevent the systematic harassment of public authorities, the Central Information Commission (CIC) has summarily dismissed a massive batch of 43 second appeals filed by Satish Ashok Sherkhane. The ruling reaffirms the Commission's stance against the misuse of the Right to Information (RTI) Act for settling personal service grievances.

A Legacy of Litigation

The appellant, a former employee of India Government Mint (IGM), Mumbai, has engaged in a protracted legal battle with the Security Printing & Minting Corporation of India (SPMCIL) and its various units for years following his dismissal from service. The Commission noted with concern that the appellant has filed over 300 RTI applications, with previous benches observing that he is a "cantankerous, disgruntled employee" intent on harassing the public authority.

Despite explicit warnings in earlier orders—including a landmark dismissal on March 18, 2024—the appellant continued to inundate the system with requests. The latest batch of appeals involved minor variations of previously rejected queries, ranging from requests for internal file notings on caste verification to specific details regarding legal counsel payments.

The Public Authority’s Defense: Privacy vs. Disclosure

The Respondents, represented by various CPIOs from units including IGM Mumbai, Kolkata, Noida, and Hyderabad, consistently denied the information. The primary justifications cited were:

• Section 8(1)(j): The information sought—such as individual employees' caste certificates, residential addresses, and personal service history—constituted "personal information" with no nexus to public activity or interest.
• Voluminous Requests: Several appeals were rejected as being too broad and comprehensive, imposing an undue burden on the department’s limited administrative resources.
• Frivolity: SPMCIL argued that the appeals were repetitive and constituted "constructive res judicata," as they sought information previously denied or irrelevant to current administrative functions.

Key Observations: The Commission’s Verdict

Presiding over the matter, Information Commissioner Anandi Ramalingam emphasized that the RTI Act was never intended to be a weapon of attrition.

> "The Commission... notes that the Appellant has filed the instant set of RTI Application(s) much after the issuance of the earlier order... wherein he was strongly advised against filing repetitive RTI Applications... the Commission’s advice and stricture has clearly gone unheeded."

The Commission further critiqued the appellant's attempt to clothe his service grievances in the mandate of the RTI Act, noting:

> "The Appellant by his own admission having approached appropriate forums to secure justice appears to be continuing with his apparent indulgence in filing such nature of RTI Applications to merely harass the public authority."

The Finality of the Decision

The CIC underscored that SPMCIL's compliance with administrative directions regarding caste verification by district authorities was already documented, and the appellant’s attempt to challenge the process through piece-meal RTI requests was invalid.

By dismissing these 43 appeals, the Commission has set a boundary: repetitive RTI filings that do not contribute to public interest but instead force Public Information Officers to cycle through the same rejected grounds will not be entertained. This decision serves as a stern reminder that the right to information is not absolute and must be exercised in good faith.

For the legal ecosystem, the order reinforces that when an applicant has received an opportunity to contest information denials through due process, the closure of such matters must be respected. The Commission has effectively signaled that service-related personal disputes should be pursued through the appropriate labour courts or tribunals, rather than attempting to overload the RTI mechanism.