Table of Contents

PIO/FAA officer's handbook — the complete reference (2026)

⚠️ DPDP Rules, 2025 (14 Nov 2025) amended Section 8(1)(j) of the RTI Act — public-interest override now under Section 8(2). Read the note →

· 2026/04/19 05:02

The lead. A Public Information Officer (PIO) carries personal liability under §20 of the RTI Act. A wrong refusal can mean ₹250/day (up to ₹25,000) deducted from your salary. A First Appellate Authority (FAA) is the first independent reviewer of a PIO decision. This handbook covers everything both roles need to know — duties, deadlines, exemptions, appeal procedures, and the case-law that has shaped each.

The PIO role

Every public authority must designate a PIO (Public Information Officer) under §5(1) of the RTI Act. The PIO is the single point of contact for citizens seeking information. Duties:

  1. Receive the application and acknowledge it
  2. Decide within 30 days (48 hours for life/liberty)
  3. Reply with the requested information OR a reasoned rejection citing a specific §8 sub-clause
  4. Transfer under §6(3) within 5 days if the information is held by a different PA
  5. Consult third parties under §11 if information concerns them
  6. Respond to First Appeal by helping the FAA review
  7. Respond to Second Appeal at the CIC/SIC stage with documentary support

The 10 §8 exemptions — when each applies

§ Exemption Practical scope
8(1)(a) Sovereignty, integrity, security Defence, intelligence, foreign relations
8(1)(b) Court-prohibited disclosure Sub judice matters
8(1)© Parliamentary privilege Information that breaches privilege
8(1)(d) Commercial confidence Trade secrets — see deep guide
8(1)(e) Fiduciary relationship Bank-customer, examiner-evaluator — see guide
8(1)(f) Foreign government Information received in confidence
8(1)(g) Endangering source/safety Informant identity, witness safety
8(1)(h) Impede investigation Live investigations only — see guide
8(1)(i) Cabinet papers Until decision is taken — see guide
8(1)(j) Personal information Post-DPDP §44(3) — see critical guide

Public-interest override: Even where a §8 exemption applies, the PIO must disclose if the larger public interest outweighs the harm. This is a discretionary judgment — and it is the most-litigated test in RTI law.

The FAA role

The First Appellate Authority is typically an officer one rung above the PIO in the same public authority. The FAA hears appeals against:

FAA disposal timeline: 30 days from filing, extendable by 15 days with written reasons (§19(6)). Beyond 45 days, the appellant can file Second Appeal directly.

The FAA must give a reasoned, speaking order — see Bhagat Singh v. CIC (Del HC 2007). Non-speaking orders are routinely quashed by the CIC.

Penalty risk under §20

The Commission can impose ₹250/day (max ₹25,000) on a PIO who:

In 2025, CIC imposed penalties on 612 PIOs (CIC Annual Report 2024-25). Reading recent §20 orders is the best inoculation.

The 25-article PIO/FAA cluster

Cluster 1 — Foundations:

Cluster 2 — Section 8 deep dives:

Cluster 3 — PIO procedure:

Cluster 4 — FAA procedure:

Cluster 5 — Case law and practical scenarios:

Tools for officers

Recent shifts (2025-26)

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