Vinubhai Haribhai Malaviya v. State of Gujarat

Vinubhai Haribhai Malaviya v. State of Gujarat (Supreme Court of India, 2019-10-16) (2019) 17 SCC 1 is a ruling on the Right to Information Act, 2005 — Section Magistrate supervision. Magistrate has continuing supervisory role over investigation. The Magistrate has a continuing supervisory role over police investigation under §156(3) and §173(8) CrPC.

Magistrate has continuing supervisory role over investigation.

The Magistrate has a continuing supervisory role over police investigation under §156(3) and §173(8) CrPC. Further investigation can be ordered even after submission of police report. Useful complement to RTI for FIR-not-registered cases.

• Section Magistrate supervision

Magistrate can order further investigation; complements §156(3) jurisdiction.

• Citation: (2019) 17 SCC 1
• Court: Supreme Court of India
• Date: 2019-10-16
• Outcome: disposed
• Reporter / Cause-list: (2019) 17 SCC 1

This ruling is part of the 300+ case-law corpus at RTI Wiki Case-law Database. Every named case sets a precedent that you can cite in your own §19(1) First Appeal or §19(3) Second Appeal. Information Commissions and FAAs are bound to consider properly cited authority.

1. Day 30 — silence by PIO = deemed refusal under §7(2). File §19(1) First Appeal in 30 days using First Appeal Builder.
2. Day 60-90 — if FAA also refuses, file §19(3) Second Appeal to the State Information Commission (or CIC for central authorities).
3. Beyond 18 months pending — writ petition under Article 226 to the High Court.
4. Parallel CPGRAMS complaint at pgportal.gov.in for service-delivery push.

Use our Citation Formatter to format the citation correctly. Pair with Bhagat Singh v. CIC (2007) (procedural objections) and Adesh Kumar v. UoI (2014) (irrelevance is not a ground) — these two Delhi HC rulings cover most everyday refusal scenarios.

• CPIO Supreme Court v. Subhash Chandra Agarwal (Constitution Bench) — office of CJI is public authority
• Anjali Bhardwaj v. UoI — IC vacancies + transparency
• Girish Deshpande — §8(1)(j) personal information test
• Bhagat Singh v. CIC — procedural compliance
• Adesh Kumar v. UoI — irrelevance is not a ground
• Full case-law database (300+)

• AI RTI Drafter
• First Appeal Builder
• Master directory of landmark RTI rulings
• RTI Act, 2005

• RTI Case-Law Search — full corpus
• PIO/FAA Knowledge Base
• 10 landmark Supreme Court RTI rulings
• High Court RTI rulings
• Landmark CIC decisions
• RTI Act, 2005 — full text

Last reviewed: 23 April 2026.