Repetitive RTI Applications on Same Subject Matter Constitute Harassment: Central Information Commission Dismisses Multiple Appeals - 2025-09-24

The Endless Cycle: CIC Cracks Down on Habitual RTI Litigant

In a robust reaffirmation of the principle that the Right to Information (RTI) Act is a tool for transparency and not a mechanism for harassment, the Central Information Commission (CIC) has summarily dismissed a massive batch of second appeals filed by a former employee of the Security Printing & Minting Corporation of India (SPMCI). Hon’ble Commissioner Anandi Ramalingam, presiding over the case, clarified that repeatedly seeking redundant or minor variations of previously addressed information constitutes an abuse of the RTI framework.

A History of Vexatious Litigation

The appellant, Satish Ashok Sherkhane, has been a perennial presence before the Commission. Over the years, he has filed an staggering number of RTI applications against SPMCIL. The Commission observed that in the current set of appeals—numbering several dozen—the appellant was re-litigating matters that had already been thoroughly adjudicated, both by various benches of the CIC and through departmental proceedings.

The judgment references a consistent trend in the appellant’s behavior, noting that in previous decisions, he has been described as a "cantankerous, disgruntled employee" who uses the RTI Act to settle personal scores rather than to further public interest.

Reasoning: When Transparency Becomes Harassment

The Commission relied on the principle of constructive res judicata , as established in the landmark judgment Mr. Ramesh Chand Jain Vs DTC (2014) . The core principle identified is simple: once an applicant has been given the opportunity to obtain information on a specific subject, they cannot return to the well—repeatedly asking for bits and pieces that they may have forgotten, or framing the same questions in different linguistic guises.

As the Commission aptly put it: > "The Commission noticed that several applicants seek some information from one wing of the public authority and based on the responses file a bunch of RTI questions from the same or other wing of same public authority... This will have a continuous harassing effect on the public Authority."

Key Observations

The Commission’s patience with the repetitive nature of these applications was explicitly stated in its findings: * "The Commission... observes that the Appellant is in the habit of providing bald arguments having no substance or relevance with the information sought." * "Taking note of the above, it was noted that another set of applications were pending with the registry which clearly contain frivolous and repeated queries." * "Cases of disclosure of information to the repetitive applicants for their private purpose which promotes their private interest but not the public interest would cause substantial harm to the legitimate aim of the Right to Information Act."

Final Verdict: The Door is Closed

The CIC dismissed all appeals within this batch, finding that the provided replies were adequate and that the appellant’s attempt to challenge those replies was based on "alleged documentary evidences" that lacked legal weight. The decision serves as a warning to potential litigants: the Commission will no longer entertain a "never-ending stream of questions" that serve only to stifle the resources and functioning of public authorities.

By upholding the CPIO's and FAA's denials—often citing Section 8(1)(j) regarding the personal information of third-party employees—the CIC has reaffirmed that the RTI Act protects the privacy of individuals and the operational integrity of public institutions from being weaponized by individuals with personal grievances.