M3, Receiving an RTI Application, The 30-day Clock

Module 3 of 10. Reading time about 35 to 45 minutes. End-of-module quiz unlocks Module 4.

This module is about the first ten minutes after an application reaches your desk. If those ten minutes are correct, the rest of the thirty days follow naturally. If they are wrong, you will already be late on day one, and the section 20 risk has begun to accrue.

Under section 6(1) and section 5(2), an application is validly received by any of the following routes.

1. Hand-delivered to the PIO or APIO at the office. Front office stamping is sufficient.
2. By ordinary post or registered post. The date of receipt at the office post bag is the start date.
3. By an online RTI portal. For Government of India, this is the rtionline.gov.in portal. For many State Governments, similar portals exist.
4. By e-mail to the official e-mail ID of the PIO if the public authority has notified that route. Where no e-mail route is notified, you may still accept the application as a courtesy, but the postal or portal route remains the controlling date for timelines.
5. Through an APIO at a sub-divisional office under section 5(2). The APIO has five days to forward to the PIO, and the section 7(1) clock starts from the date the APIO received the application plus five days, as a maximum.

The first thing your office must do is date-stamp every application. The stamp must show the date, the inward number, and the receiving officer's signature. If your office uses an inward register, the application must be entered against a serial number on the same day. The CIC has, in a series of orders, treated absence of a date stamp as proof of internal mishandling and attributed the resulting delay to the PIO.

As a PIO, you should run a weekly check on the inward register. Any application that has crossed seven days without a draft reply is a red flag.

You must maintain an RTI register at the PIO desk. The standard fields are: serial number, date of receipt, name of applicant, address of applicant, contact number, e-mail, mode of receipt, fee paid and mode of payment, BPL status if claimed, subject matter in two lines, file or section to which marked, date of any section 6(3) transfer, date of section 11 third-party notice if issued, date of draft reply, date of dispatch, fee challan reference if additional fee demanded, and disposal status. This register is your defence in any complaint under section 18 or second appeal under section 19(3).

For Central Government public authorities, the application fee under the Right to Information (Regulation of Fee and Cost) Rules 2005 is ten rupees, payable by demand draft, banker's cheque, or postal order, or through the online RTI portal. State Governments have their own rule with the same or lower fee, some States have set the fee at five rupees and a few at twenty rupees.

If the applicant is below poverty line, no application fee is payable. The applicant must produce a copy of the BPL certificate or any document showing BPL status. The CIC has held that the absence of a BPL card is not a ground to demand fee if the applicant has submitted a self-declaration with a supporting ration card or any State BPL document. Always lean towards accepting the BPL claim and ask for documentary support only if there is a real doubt.

If the public authority fails to comply with the time limits under section 7(1), the information shall be provided free of charge. This is not a punishment, it is a statutory consequence. As a PIO, if you have crossed thirty days, you cannot demand the per-page fee for the reply.

If supplying the information requires charges beyond the application fee, the PIO must issue a written intimation under section 7(3) within thirty days, calculating the cost as per the prescribed rules. The intimation must show the rate per page, the number of pages, and the total amount. The intimation must give the applicant a chance to seek review under section 7(3)(a).

The thirty-day clock is paused from the date of the fee intimation until the date of receipt of the additional fee, under the proviso to section 7(1). Use this pause sparingly and only when it is genuinely required.

For Central Government, demand drafts and Indian Postal Orders are universal. Many States accept court fee stamps. The online RTI portal accepts UPI and net-banking. The CIC has held that refusal to accept a valid mode of payment is a denial of access and attracts section 7(8) review.

Section 6(3) applies when the public authority receiving the application does not hold the information or the information is more closely connected with the functions of another public authority. The PIO must transfer the application to the right public authority within five days of receipt and inform the applicant in writing of the transfer.

1. When the information is partly with you and partly with another authority. Here, you reply on the part you hold and indicate the other authority for the rest. You do not transfer the whole application.
2. When the information has been migrated to an archive that is still under your control. You retrieve it.
3. When the information has been routinely shared with you by another authority and is held in your records. You disclose what you hold.
4. When the other authority is not a public authority within section 2(h). Here you decline with reasons.

The transfer letter under section 6(3) must contain the inward reference number, the date of receipt, the subject matter, the section 6(3) ground, the address of the receiving authority, and the name and address of the applicant for direct communication. Mark a copy to the applicant on the same day. The five-day count is calendar days, not working days, by the prevailing CIC view.

Splitting the application into many transfers and copies, the so-called “scatter transfer”, has been frowned upon by the CIC. If the application is genuinely multi-authority, you may transfer to the principal authority and inform the applicant of the others. Do not generate twenty transfer letters when one will do.

The thirty days run from the date of receipt at the public authority, not the date of marking to the PIO. If the application reached the post room on day zero and was marked to you on day five, you still have only twenty-five days.

The thirty days are calendar days, including holidays and weekends. The reply must be dispatched on or before the thirtieth day. If the thirtieth day is a holiday, dispatch on the previous working day. Do not gamble on the General Clauses Act extension argument, the CIC has not consistently accepted it for RTI.

Under the proviso to section 7(1), if the information concerns the life or liberty of a person, the reply must be in forty-eight hours from receipt. As a PIO, treat any application that mentions imminent harm, custody, medical emergency, or environmental hazard as a life-liberty matter and clear it the same day or next day at the latest. A wrong call here will cost you under section 20.

When you transfer under section 6(3), the thirty days run from the date the new authority receives the application. However, the outer limit cannot exceed thirty-five days from the original date of filing, because the transferor has five days to act under section 6(3) and the transferee has thirty days under section 7(1). As a transferee PIO, your time begins on receipt at your office.

If section 11 third-party consultation is triggered, the time taken for consultation is not counted in the thirty-day period under section 7(1). The maximum consultation time is forty days from receipt of the application, so the absolute outer limit is forty days plus thirty days, i.e., seventy days from receipt.

If the applicant is illiterate, asks for help framing the request, or asks for the procedure to inspect records, the PIO has a duty to render reasonable assistance. The CIC has read this duty broadly. Even where a public authority has a help desk, the PIO is the named officer. If you cannot help personally, deputise a clerk in writing under section 5(4) and inform the applicant of the deputy's contact.

At the receipt stage you must scan the application for the following triggers and flag them.

1. The request names another person or organisation.
2. The request asks for documents that originate from another authority and were submitted as confidential.
3. The request asks for tender or contract details that contain a private party's commercial information.
4. The request asks for personnel records of an officer or employee other than the applicant.

If any trigger is present, section 11 third-party consultation must begin within five days of receipt. Do not wait until day twenty-five.

Although the Act does not mandate a receipt acknowledgement, sending one within three days is best practice. The acknowledgement should carry the inward number, the date of receipt, the name of the PIO, the contact number, the section 19(1) FAA contact, and a one-line note that the reply will be dispatched on or before the thirtieth day. This courtesy reduces complaints and shows good faith if a section 20 hearing arises.

1. Day 0, application received at the front office of a Central Government Ministry. Date stamp affixed, inward number assigned.
2. Day 1, application marked to the PIO. Register updated.
3. Day 2, PIO scans the application, identifies that part of the information is held by an attached office. PIO does not transfer the whole application, replies on the part held, and informs the applicant of the attached office.
4. Day 3, PIO identifies a section 11 third-party trigger on item 4 of the application. Section 11 notice issued, ten-day clock starts.
5. Day 13, third party submits representation under section 11.
6. Day 15, PIO records a reasoned order on the third-party objection, deciding to release after redaction under section 10.
7. Day 25, PIO issues a section 7(3) additional fee intimation for items 1 and 2 that require photocopy of 120 pages. The clock pauses from day 25.
8. Day 28, applicant deposits the additional fee. Clock resumes.
9. Day 33, PIO dispatches the full reply with redacted documents, severability note, exemption analysis, and FAA contact.

The PIO is within time because of the section 7(7) pause and the section 7(3) pause.

1. Accepting an application but not stamping or registering it.
2. Asking the applicant to specify a reason or purpose, in violation of section 6(2).
3. Insisting on an exact format. The Act does not prescribe a form. Any written request that gives the applicant's name, address, and the information sought is valid.
4. Refusing the application because it is in a regional language. Under section 6(1) the application may be in English, Hindi, or the official language of the area.
5. Calling the applicant to clarify on the phone and not recording the call. Always reduce clarifications to writing.
6. Sending the file to a junior for marking and forgetting it. The PIO is personally accountable for the timeline.

Many citizens use the RTI route to ventilate grievances. The PIO must distinguish a request for information from a complaint. If the application asks for redressal of a grievance, the PIO may treat the grievance portion under the public grievance mechanism of the authority and reply separately on the information portion. Do not reject the whole application as a grievance. Sever and reply.

If the application seeks a very large volume of records, the PIO may invite the applicant for inspection under section 2(j), prepare an indexed inspection schedule, and supply only the records the applicant marks. The right to copies remains with the applicant. The CIC has approved this approach where the volume is genuinely vast, but has rejected it where the PIO used it as a delaying tactic for ten or twenty pages.

This module gave you the receipt and clock framework. In Module 4 you will translate this into a drafting template, including the section 10 severability note, the section 8 exemption analysis, and the boilerplate that protects you in the FAA hearing.

For the citizen's view of the receipt stage, see How to file an RTI and RTI fees explained on RTI Wiki.

This module is part of the RTI Wiki PIO Certification Course. The course is a Learner Certificate programme. It is NOT accredited by any government or statutory body. The drafting exercises in Module 7 are evaluated by a Large Language Model trained on RTI Wiki content, not by human evaluators. Scores are indicative knowledge measures, not legal advice.

Now take the M3 quiz to proceed to M4.