Table of Contents

Module 02 — §4 suo-motu disclosure compliance audit

RTI for Activists & NGOs Module 02

Goal: Use §4 to expose what authorities should be publishing but aren't.

What §4(1)(b) requires

17 categories every public authority MUST publish suo motu (without an RTI request):

  1. (i) particulars of organisation
  2. (ii) powers + duties of officers + employees
  3. (iii) decision-making procedure
  4. (iv) norms for discharge of functions
  5. (v) rules + regulations + manuals
  6. (vi) categories of documents held
  7. (vii) particulars of consultative bodies
  8. (viii) directories of officers
  9. (ix) salary scales
  10. (x) budget
  11. (xi) subsidy programmes
  12. (xii) beneficiary lists [killer one]
  13. (xiii) concessions, permits granted
  14. (xiv) electronic records held
  15. (xv) facilities for citizen info
  16. (xvi) PIO names
  17. (xvii) any other

§4(1)(b)(xii) — the beneficiary list

Every public authority must publish lists of beneficiaries of programmes it administers. Almost no authority complies. That non-compliance is itself the story.

Campaign template:

  1. File 1-question RTI: “Provide the §4(1)(b)(xii) beneficiary list for [scheme] for FY [year], as required by the RTI Act.”
  2. PIO can't refuse — it's a mandatory disclosure.
  3. PIO either provides (publishable) or refuses (which is itself a §20 penalty motion).

Compliance audit framework

Build a §4 compliance scorecard for any authority:

  1. Visit the authority's website.
  2. For each of the 17 §4(1)(b) categories, mark: published / partial / missing / outdated.
  3. Score out of 17.
  4. Cross-link RTI for what's missing.

NGO Centre for Civil Society + Transparent Chennai have done this for ULBs — typical score is 6-8/17.

CIC complaints under §18

Distinct from §19 appeals — §18 is a complaint to the CIC/SIC about systemic non-compliance with §4 (or §6, §7). No fee. No 30-day limit.

Use §18 when:

  1. Authority repeatedly fails to publish §4 disclosures
  2. PIO is unidentifiable
  3. There's no decision to appeal (because there's no acknowledged application)

§18 can result in CIC penalty under §20 against the authority's chief.

Public-interest petition follow-up

After CIC issues directions on §4 non-compliance, file a PIL in the relevant HC if compliance still doesn't follow. Major precedent: *DAV College Trust v. Director of Public Instructions* — schools must publish under §4 even though they're aided NGOs.

✅ Quiz

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Last reviewed: 24 April 2026.

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