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2026 Supreme(Online)(CIC) 4717
CENTRAL INFORMATION COMMISSION
Surendra Singh Meena, Information Commissioner
Rakesh Kumar Gupta – Appellant
Versus
LIC – Respondent
Second Appeal No. CIC/LICOI/A/2025/602022
For the Appellants/Petitioners:
For the Respondents: Madhavi Tari
A public authority must provide a consolidated, self-contained, and point-wise response to an RTI application; fragmented or piecemeal replies from the CPIO and appellate authorities are insufficient to satisfy the transparency requirements of the RTI Act, 2005.
Headnote:(A) Right to Information Act, 2005 - Sections 2(f), 2(i), 4(1)(b), 6(1), and 8(1)(d) - Respondent denied information under Section 8(1)(d) claiming commercial confidence - Information not compiled and not part of records - Interpretation of Section 4 proactive disclosures - Commission observed initial replies were piecemeal and lacked clarity - Directions issued to provide a consolidated, point-wise revised reply. (Paras 6-10)
Facts of the case:
The appellant sought extensive information regarding 'Keyman Insurance Policies' since 2005 under various sub-clauses of Section 4(1)(b) of the RTI Act. The CPIO and FAA denied the requests, citing exemptions under Section 8(1)(d) for trade secrets and stating that the information was not compiled or available as defined under the Act.
Findings of Court:
The Commission found the replies provided by the CPIO and the FAA to be piecemeal and not self-contained, failing to provide a clear, consolidated response to the appellant.
Issues: Whether the information sought regarding Keyman insurance policies was exempt under Section 8(1)(d) and whether the public authority provided an adequate and self-contained response under the RTI Act.
Ratio Decidendi: Public authorities are obligated to provide a clear, comprehensive, and self-contained reply to RTI applications; if initial responses are fragmented, a revised, point-wise reply must be provided to ensure transparency and clarity.
Result: Appeal disposed with directions to provide a revised reply within three weeks.
Relevant Facts Emerging from Appeal:
| RTI application | 29.10.2024 |
| PIO replied on | 25.11.2024 |
| First Appeal filed on | 12.12.2024 |
| First Appeal Order on | 08.01.2025 |
| 2nd Appeal received on | 11.01.2025 |
Information sought and background of the case:
The Appellant filed an RTI application dated 29.10.2024 seeking information on the following points:
“Kindly provide all the information via E mail or in DVD in soft form.
Information sought
1 Kindly provide information Section 4(1)(b) (iv) information related to Keyman insurance Policies. since 2005 to till date.
2 Kindly provide information Section 4(1)(b)(v) information related to Keyman insurance Policies. since 2005 to till date.
3 Kindly provide information Section 4(1)(b) (vi) information related to Keyman insurance Policies. since 2005 to till date.
4 Kindly provide information Section 4(1)(b) (vii) information related to Keyman insurance Policies. since 2005 to till date. In this point, only policy matter rules and regulation..
5 Kindly provide information Section 4(1)(b)(ix) information related to Keyman insurance Policies. since 2005 to till date. In this point, only department, which formulate policy matter.
6 Kindly provide information Section 4(1)(b) (xiv) information related to Keyman insurance Policies. since 2005 to till date. In this point, only policy matter rules and regulation..
7 Kindly provide information Section 4(1)(b)(xv) information related to Keyman insurance Policies. since 2005 to till date. In this point, only policy matter rules and regulation.. Specially in Delhi
8 Kindly provide information Section 4(1)(c) information related to Keyman insurance Policies. since 2005 to till date.
9 Kindly provide information Section 4(2) information related to Keyman insurance Policies. since 2005 to till date.
10 Kindly provide Keyman insurance Scheme refer in Para 5 of enclosed at Page 6-7
11 Kindly provide Inspection related to Item 1 to 10. And provide certified copies thereof (after pointing out after Inspection).”
The CPIO replied vide letter dated 25.11.2024 and the same is reproduced as under:-
“Reply 1, 2, 4 & 6. The applicant is informed that the information sought is of commercial confidence/ trade secret and intellectual property, disclosure of which can harm the competitive position of the Corporation. Hence, the information sought is exempted from disclosure under section 8 (1) (d) of the RTI Act, 2005.
Reply 3. The applicant is informed that the information sought is not compiled as it does not form part of any regulatory requirement or submission. The record as defined under section 2(i) of the RTI Act, 2005 and information as defined under section 2(f) does not exist. Hence, the information sought is not available and cannot be provided.
Reply 5. The applicant is informed that the information sought is not clear as required under section 6 (1) of the RTI Act, 2005. Hence, no information can be provided in this regard. However, in the spirit of RTI Act, 2005 it is informed that 'directory of its officers and employees' as per section 4 (1) (b) (ix) of the RTI Act, 2005 is available on LIC's website. Path as follows:
www.licindia.in Bottom links RTI Center→RTI Page SL No.ix Disclosures (A directory of its officers and employees.)
Reply 7. The applicant is informed that the information sought is not clear as required under section 6 (1) of the RTI Act, 2005. Hence, no information can be provided in this regard. However, in the spirit of RTI Act, 2005 it is informed that the details regarding 'the particulars of facilities available to citizens for obtaining information' as per section 4 (1) (b) (xv) of the RTI Act, 2005 is available on LIC's website. Path as follows:
www.licindia.in Bottom links RTI Center→RTI Page SL No.xv Disclosures (The particulars of facilities available to citizens for obtaining information)
Reply 8 & 9. The applicant is informed that the information sought is of commercial confidence/ trade secret and intellectual property, disclo
