Excessive Voluminous RTI Requests Do Not Justify Blanket Denial: Central Information Commission Orders SAI to Process Streamlined Queries - 2025-05-15

Laws, Courts & Judgments.

Balancing Transparency: CIC Refines Sweeping RTI Request in SAI Pension Dispute

In a significant decision highlighting the interpretative balance between administrative efficiency and the public’s right to information, the Central Information Commission (CIC) has offered a middle ground in a protracted dispute between a retired Sports Authority of India (SAI) official and the public organization.

Information Commissioner Vinod Kumar Tiwari presided over the appeal brought by Mangat Goyal, a 67-year-old retired Deputy Director, who had originally filed a staggering 54-point Right to Information (RTI) application. The ruling underscores that while public authorities are not obligated to compile disproportionately voluminous records, they must still facilitate the disclosure of information through reasonable and streamlined cooperation.

The Backdrop: A Retiree’s Quest for Accountability

The dispute centers on Mangat Goyal’s retirement benefits and subsequent pension adjustments made by SAI. Following his retirement in 2016, Goyal alleged that his pension was improperly reduced, leading to a long-standing grievance. In an effort to secure legal clarity, Goyal sought a voluminous set of internal notes, pay scale records, and recruitment files involving other staff.

When the SAI failed to provide the requested data, citing the voluminous nature of the request—a common defense under Section 7(9) of the RTI Act —the matter escalated through the First Appellate Authority and finally to the Commission .

Contentions at the Doorstep of Transparency

The SAI argued that compiling the 54-point request would "disproportionately divert the resources" of their organization, consistent with established precedents regarding excessive information requests. They had previously offered Goyal the opportunity to inspect the files in person, an offer the retiree declined.

However, recognizing the appellant’s genuine need for information to contest his pension reduction, the CIC facilitated a compromise during the hearing. Goyal voluntarily pared down his request from 54 points to 17 specific queries, allowing the Commission to pivot from debating the volume of the request to ensuring the specific information was actually provided.

Legal Analysis: Reasonable Cooperation

The Commission ’s analysis relied on a pragmatic application of the RTI Act. While it acknowledged that the SAI was not acting with mala fide intent by initially denying the massive request, the CIC emphasized that the Act serves as a tool for transparency.

By allowing the appellant to narrow his scope, the Commission balanced the SAI’s operational constraints with the citizen's right to know. The order effectively reinforces the principle that if an applicant is willing to restrict their request to a manageable set, the public authority is tasked with fulfilling those requirements—provided they exist within the public record.

Key Observations

The Commission ’s decision highlights the necessity of cooperation in transparency efforts:

* "It is not the case where the information sought was denied to the Appellant."

* "The Respondent replied to the Appellant that information sought was voluminous in nature, compiling and collating the same would have disproportionately diverted their resource."

* "The Appellant is advised to provide a copy of his written submission... and the Respondent is directed to provide the information/reply to the Appellant as per the records available with them."

The Road Ahead: Compliance and Closure

The CIC has directed the SAI to provide the information on the 17 restricted points within two weeks of receiving the appellant’s refined submission. This decision serves as a reminder to both public authorities and RTI applicants: the former must not use "voluminous record" claims to evade accountability, and the latter must effectively utilize the RTI framework by framing concise, relevant requests. For Mangat Goyal, this order provides a viable path to obtaining the documentation necessary to address his pension concerns, marking a victory for procedural fairness.