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.
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:
| § | 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 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.
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.
Cluster 1 — Foundations:
Cluster 2 — Section 8 deep dives:
Cluster 3 — PIO procedure:
Cluster 4 — FAA procedure:
Cluster 5 — Case law and practical scenarios:
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