Suo Motu Disclosure under Section 4 — The Proactive Duty

• Section 4(1)(b) — 17 categories of information every public authority must publish.
• Section 4(1)(c) — publish all relevant facts while formulating important policies or announcing decisions.
• Section 4(1)(d) — provide reasons for administrative or quasi-judicial decisions to affected persons.
• Section 4(2) — endeavour to disseminate proactively so that citizens need minimum recourse to formal requests.
• Section 4(3) — disseminate through notice boards, newspapers, public announcements, media, internet, or any other means.
• Section 4(4) — all dissemination “at reasonable cost of the medium in local language”.

Frame the request precisely:

Under Section 6 of the RTI Act, 2005, I request:

1. A copy of the information required to be published under
   Section 4(1)(b), sub-clauses (i) to (xvii), as they stand
   for the [department name] as on [date].

2. The date(s) on which the above information was last updated
   on the department's website, with the URL(s).

3. A copy of the complete file noting on the decision to not
   publish, if any category is deliberately withheld.

If the RTI itself is refused or delayed, complaint to the Information Commission:

Complaint under Section 18(1) of the RTI Act, 2005 against
[department name] for systemic non-compliance with Section 4.

(i)   Section 4(1)(b) requires publication of 17 categories.
(ii)  An inspection of the department's website on [date]
      shows [X] categories missing or over a year out of date.
(iii) An RTI application dated [Y] sought the same information;
      the reply was [refused / silent].
(iv)  The Commission is requested to direct publication under
      Section 19(8)(a)(i)-(vi), with a monthly progress report
      until full compliance.

The Commission has supervisory jurisdiction and can impose personal costs on the designated PIO for persistent non-compliance under Section 20.

• Anjali Bhardwaj v. Union of India, (2020) 11 SCC 345 — Supreme Court recognised the centrality of Section 4 and directed Information Commissions to supervise proactive compliance.
• CIC Decision CIC/SA/A/2013/000132 — Commission may direct a public authority to publish outstanding Section 4 categories within a time-bound schedule, with compliance reports.
• DoPT Office Memorandum No. 1/6/2011-IR dated 15 April 2013 — reiterates the 17-category obligation and prescribes templates.
• Subhash Chandra Agarwal v. CPIO SC, (2020) 5 SCC 481 — Supreme Court administrative side is a public authority; proactive disclosure applies.

1. Open the department's official website. Look for a link named “RTI”, “Right to Information” or “Transparency”.
2. Spot-check 5 of the 17 categories — PIO list, directory of officers, budget, rules, monthly remuneration. If any is missing or older than a year, Section 4 is not complied with.
3. Screenshot the website with the URL and date visible. That is your evidence.
4. File an RTI using the wording above.
5. On refusal or delay, file a Section 18 complaint with the Information Commission within 90 days.
6. Attend the hearing — complaints on systemic issues rank higher than individual appeals.

Include a request for the Section 4 compliance report in your RTI. Many departments file an annual Section 4 self-audit to the Information Commission. Asking for that report is a fast way to reveal the gap between claim and reality.

Not as such, but Section 19(8)(b) empowers the Commission to award compensation to an applicant harmed by inaction. Section 4 non-compliance combined with Section 6 refusal often supports a compensation claim.

Only if they qualify as public authorities under Section 2(h). The Thalappalam test applies.

Any format readable on a standard browser — HTML pages, PDFs, machine-readable tables. Scanned PDFs with no OCR are legally compliant but practically unhelpful; the Commission has cautioned against them.

At least annually under Section 4(1)(b) read with DoPT guidelines. Items that change more frequently (budget allocations, pay orders) must be updated as soon as they are revised.

After the 14 November 2025 amendment to Section 8(1)(j) by DPDP Rules 2025, personal information of third parties (e.g., beneficiaries' names with addresses) is tested against the amended privacy proviso. Aggregate or suitably-redacted data remains disclosable.

Spend 10 minutes today on any department's website. Open the “RTI” link. Count how many of the 17 categories are current. For every gap, you have a Section 4 case. Use the templates above. Start with our First RTI template and adapt.

• The RTI Act, 2005 (as amended)
• All explanations
• Public authority — Section 2(h)
• Substantially financed — Thalappalam test
• Speaking-order requirement — Section 7(8)
• Missing files under RTI
• Deemed CPIO — Section 5(5)
• First RTI template
• First Appeal template
• Why RTI gets rejected
• Inspection under RTI
• PIO reply after DPDP 2025

1. Right to Information Act, 2005, Section 4 read with Sections 2(h), 6, 18, 19.
2. Department of Personnel and Training, Office Memorandum No. 1/6/2011-IR dated 15 April 2013.
3. Anjali Bhardwaj v. Union of India, (2020) 11 SCC 345.
4. Subhash Chandra Agarwal v. CPIO SC, (2020) 5 SCC 481.
5. Central Information Commission, Annual Report 2023-24.
6. Thalappalam Service Coop. Bank Ltd. v. State of Kerala, (2013) 16 SCC 82.

Last reviewed on: 21 April 2026