Laws, Courts & Judgments.

RTI Act Cannot Be Used for Grievance Redressal or Seeking Opinions, Rules Central Information Commission

In a recent set of rulings, the Central Information Commission (CIC) has reaffirmed the foundational boundaries of the Right to Information (RTI) Act, 2005. Presided over by Information Commissioner Anandi Ramalingam, the Commission dismissed a series of appeals and complaints filed by G. Sankar against the Reserve Bank of India (RBI), clarifying that the RTI framework is not a tool for redressing personal grievances or extracting legal opinions from public authorities.

The Background: When RTI Meets Personal Grievances

The dispute arose from multiple RTI applications filed by the appellant, which sought information regarding his personal banking history, specific loan accounts at private banks, and his credit score records as maintained by CIBIL TransUnion. Rather than seeking existing records, the appellant’s queries frequently demanded reasons for bank actions, requested hypothetical interpretations of the RBI Act, and aimed to resolve disputes concerning account classifications.

The CPIO of the Reserve Bank of India consistently maintained that the requested information was either unavailable or did not qualify as “information” under the definition provided in Section 2(f) of the RTI Act.

Legal Analysis: Defining the Scope of Information

The Commission’s decision serves as a stern reminder of the limitations of the RTI Act. Commissioner Ramalingam emphasized that the Act is designed to provide access to existing records and documents held by a public authority. It does not mandate that the Central Public Information Officer (CPIO) provide advice, opinions, or deductive reasoning to resolve disputes.

The CIC drew heavily upon established Supreme Court precedents:

* CBSE vs. Aditya Bandopadhyay : The apex court clarified that public authorities are not required to furnish information requiring the drawing of inferences, assumptions, or the provision of opinions.

* Khanapuram Gandaiah vs. Administrative Officer : The court held that an applicant is only entitled to information that a public authority can access under the law, not answers to "why" a particular decision was made.

* Dr. Celsa Pinto vs. The Goa State Information Commission : This ruling established that "justifications" for actions fall outside the scope of "information" as defined by Section 2(f).

Key Observations

The Commission highlighted the strain placed on public officials by overly broad and interrogative RTI requests:

> "The Appellant/Complainant shall note that outstretching the interpretation of Section 2(f) of the RTI Act to include deductions and inferences to be drawn by the CPIO is unwarranted as it casts immense pressure on the CPIOs to ensure that they provide the correct deduction/inference to avoid being subject to penal provisions."

Furthermore, addressing the nature of the complaints, the CIC observed:

> "Proceedings under the RTI Act cannot be converted into proceedings for adjudication of disputes as to the correctness of the information furnished."

The Verdict and Its Implications

The Commission concluded that the CPIO’s responses were in accordance with the Act and found no grounds to invoke penal provisions under Section 20. By dismissing the appeals, the CIC has signaled that the RTI process has a specific, defined purpose.

For future litigants, this judgment acts as a defensive shield for public authorities, reinforcing that while transparency is a cornerstone of governance, the RTI Act does not empower citizens to force public institutions to act as legal advisors or secondary courts of appeal for personal banking or service disputes. Citizens seeking redresses for such grievances are directed to approach the appropriate regulatory bodies or ombudsman services instead.