RTI for blood bank records

Ramesh's mother needed two units of blood before her surgery. The hospital sent him to a blood bank across town. The bank charged a high “processing charge”, gave him blood from a unit he could not trace, and offered no paper to show the blood had been tested. After the transfusion his mother ran a fever for a week. Ramesh never found out whether that unit was safe.

When a blood bank will not answer your questions, the Right to Information Act is the tool that forces it to show its records. This guide explains, in plain steps, which authority holds those records, what to ask for, what the fee is, and how to escalate if you are refused.

A blood bank is not a private shop. It is licensed under the Drugs and Cosmetics Act 1940 and the Drugs and Cosmetics Rules 1945, Part X-B (Rules 122F to 122P). Under section 3(b) of the Act, blood is treated as a “drug”, so every blood bank must hold a licence to collect, test, store and issue blood.

The licence is granted in Form 28C under Rule 122G. The bank applies in Form 27C, and the renewal certificate is issued in Form 26G. A licence is valid for five years under Rule 122H. Renewal is not automatic — the bank must reapply and pass inspection.

Licensing is dual. The State Drugs Controller is the State Licensing Authority. It processes the file and forwards it to the Central Licence Approving Authority (the DCGI office within CDSCO) for final approval. This means the State Drugs Controller holds the inspection reports, stock records and licence file, and it is a public authority under the RTI Act.

On top of the drug law, the National AIDS Control Organisation (NACO) and the National Blood Transfusion Council (NBTC) set policy for blood transfusion services under the Ministry of Health and Family Welfare. At state level the State Blood Transfusion Council (SBTC) and the State AIDS Control Society (SACS) run these services. These bodies are also public authorities.

The Supreme Court put this whole structure in place. In Common Cause v. Union of India, (1996) 1 SCC 753 (decided 4 January 1996), the Court directed the licensing of all blood banks, the setting up of National and State Blood Transfusion Councils, and the elimination of professional donors. That judgment is the backbone of blood safety law in India.

These are the records a blood bank must keep, and that you can request through the State Drugs Controller:

1. Blood stock register — units collected, issued, and in stock on a given date.
2. Donor screening audit — how many donors were screened and how many were deferred, in aggregate.
3. Mandatory test records — every unit must be tested for HIV, Hepatitis B, Hepatitis C, Syphilis (VDRL) and Malaria. Ask for the count of units tested and the count of positive units destroyed.
4. Transfusion-reaction register — adverse reactions reported by hospitals that used the bank's blood.
5. Licence renewal status — current Form 26G certificate, expiry date, and any inspection observations.
6. Record-retention proof — under Rule 122P, the bank must keep all records for five years.

Ask for aggregate, audited numbers, not individual donor files. Donor identity is personal information protected under section 8(1)(j) of the RTI Act. A PIO can refuse a request for donor names, and rightly so. For a full explanation of how this exemption works and how to word your request around it, see the s8(1)(j) framework.

Many older guides tell you to demand “NAT-PCR test records” as if NAT were compulsory. It is not. NAT (nucleic acid testing) is a more sensitive test that catches infections earlier than the standard tests. The NBTC classifies it as “optional but recommended”.

On 13 March 2026 the Supreme Court declined to judicially mandate NAT in every blood bank, in a PIL filed by the Sarvesham Mangalam Foundation. The Government has also rejected making NAT compulsory nationwide. So there is no mandatory NAT register every bank must keep.

The right question to ask is: “Does this blood bank conduct NAT testing? If yes, on what proportion of units?” That is a factual, answerable question about the bank's own practice — not a demand for a register that may not exist.

Your first stop is the State Drugs Controller (also called the State Licensing Authority for drugs). This office holds the licence file, the inspection reports and the stock records of every licensed blood bank in the state. For a private blood bank, this is your best route, because the regulator holds the records even though the bank itself is private. This is called the “reach-through” route under section 2(f) of the RTI Act. For the full method, see RTI to a private body through its regulator.

If your question is about blood safety policy, the State Blood Transfusion Council, or an AIDS-control programme, file to the State Blood Transfusion Council (SBTC) or the State AIDS Control Society (SACS) instead. For a Central question — such as CDSCO's approval of a particular bank's licence — file to the Central Drugs Standard Control Organisation under the DCGI.

If you are not sure which authority to pick, file two applications: one to the State Drugs Controller for the bank's operational records, and one to the SBTC for the policy and audit side. This doubles your chances of a complete answer.

Under the RTI Rules 2012, the fee for a Central Government public authority is Rs.10. You can pay by cash, Indian Postal Order, demand draft, banker's cheque, or electronic means. If you hold a Below Poverty Line (BPL) certificate, you are exempt from the fee — attach a copy of the certificate.

State-level fees vary. Some states charge Rs.10, some charge nothing, some charge more for certain requests. Check your state's RTI rules before you file. The how-to-file-RTI guide lists the state-wise position.

1. Step 1 — Identify the authority. Pick the State Drugs Controller for a single bank's records, or the SBTC/SACS for policy and audit questions.
2. Step 2 — Write the application. Address it to the Public Information Officer of that authority. State that it is an application under section 6 of the RTI Act 2005.
3. Step 3 — List your questions. Use the list above. Keep each question short and numbered. Ask for aggregate data, not donor names.
4. Step 4 — Attach the fee. Rs.10 by IPO, cash receipt, or electronic payment. Attach a BPL certificate if you have one.
5. Step 5 — Submit. Hand it in at the office, send it by registered post, or use your state's online RTI portal.
6. Step 6 — Wait 30 days. The PIO must reply within 30 days (48 hours if the question involves a person's life or liberty — a transfusion-reaction query may qualify).

A ready template follows. Copy it, fill in the bank's name, and you are ready to file.

To: The Public Information Officer
    Office of the State Drugs Controller, [State]

Subject: Application under section 6, RTI Act 2005 —
        Blood bank records of [name and address of blood bank]

Sir/Madam,

[Name of blood bank], licensed under Form 28C of the
Drugs and Cosmetics Rules 1945, operates in [city]. Please
furnish the following information for the period
[dd/mm/yyyy] to [dd/mm/yyyy]:

1. Blood stock register: units collected, issued and in
   stock, month-wise, in aggregate.
2. Donor screening audit: number of donors screened and
   number deferred, in aggregate.
3. Mandatory TTI testing: number of units tested for HIV,
   Hepatitis B, Hepatitis C, Syphilis (VDRL) and Malaria;
   number of positive units destroyed.
4. Whether the bank conducts NAT testing, and if yes, the
   proportion of units on which NAT was performed.
5. Transfusion-reaction register: adverse reactions
   reported, in aggregate.
6. Current licence status: Form 26G renewal certificate,
   expiry date, and inspection observations from the last
   inspection.

I seek aggregate, audited data and not donor identity.

Fee: Rs.10, paid by [IPO / cash / electronic payment].
     [BPL certificate attached, if applicable.]

Date: [dd/mm/yyyy]              [Your name and address]

1. Asking for donor names. This is personal information under s8(1)(j). The PIO will refuse it, and the refusal will be correct. Ask for aggregate numbers instead.
2. Demanding a “NAT register”. NAT is not mandatory, so such a register may not exist. Ask whether NAT is done and on what share of units.
3. Filing only to “NACO”. NACO is a central body. It will not hold one private bank's stock register. File to the State Drugs Controller for bank records, and to the SBTC or SACS for the state-level programme.
4. Filing to the blood bank directly. A private blood bank is not itself a public authority. You reach it through its regulator under s2(f). Filing straight to the bank will get you nothing.
5. Vague dates. Always give a date range. “All records” lets the PIO claim the request is too broad.

1. First appeal — section 19(1). If the PIO does not reply within 30 days, or gives a wrong or partial reply, file a first appeal with the First Appellate Authority in the same department within 30 days of the deadline. The first-appeal guide walks you through the format and deadlines.
2. Second appeal — section 19(3). If the first appeal also fails, file a second appeal to the Central Information Commission (for Central authorities like CDSCO) or the State Information Commission (for state authorities). You have 90 days to do this. The second-appeal guide explains the filing route.
3. Complaint to the regulator. Alongside RTI, you can complain to the State Drugs Controller about a specific safety failure — untested blood, expired licence, or a transfusion reaction. The controller can inspect the bank and suspend its licence under Rule 122P.
4. Consumer or civil route. If a bad transfusion caused injury, combine your RTI evidence with a medical-negligence action. See RTI for a medical negligence enquiry.

The ladder is simple: authority → first appeal → Information Commission → regulator complaint → court. RTI gets you the proof at each rung.

1. Pair your filing. One application to the State Drugs Controller for the bank's records, one to the SBTC for the state programme. Cross-check the two replies.
2. Ask about the licence, not just the blood. A bank with an expired or conditional licence is a red flag. The Form 26G certificate and the last inspection report tell you more than the stock register alone.
3. Use the life-or-liberty clause. If a transfusion reaction is active and someone is at risk, cite the 48-hour reply rule under section 7(6) of the RTI Act.
4. Quote Common Cause. Naming (1996) 1 SCC 753 reminds the PIO that blood safety is a Supreme Court-mandated structure, not a favour.

• Q: Can I get the rare-donor registry? A: You can ask the SBTC or a major government blood centre for the aggregate size of the rare-donor registry and the protocol for accessing it. You cannot get donor identities.
• Q: The hospital and the blood bank blame each other for a reaction. A: File RTI to both — to the hospital for the transfusion-reaction report and patient records, and to the State Drugs Controller for the bank's reaction register and test records. Hospital licence RTI covers the hospital side.
• Q: Is a “professional donor” still legal? A: No. Common Cause (1996) directed the elimination of professional donors. Ask the State Drugs Controller whether the bank has any record of paid donors.
• Q: The bank says it is private and not under RTI. A: The bank is right that it is not a public authority — but its regulator is. File to the State Drugs Controller, which holds the bank's inspection and licence records under the reach-through route in s2(f).

• RTI for a hospital licence
• RTI for a medical negligence enquiry
• RTI to a private body through its regulator
• The s8(1)(j) personal-information framework
• How to file an RTI application in India
• File a first appeal under section 19
• Second appeal to the CIC or SIC

• The RTI Playbook — our full step-by-step handbook for drafting, filing and escalating RTI applications, with ready-to-use templates for every public authority.
• Support RTI Wiki — if this guide helped you hold a blood bank to account, your donation keeps these plain-language explainers free and updated.

1. CDSCO, *Guidelines for Blood Bank licensing* (Form 27C / 28C / 26G, Rules 122F–122P) — https://cdsco.gov.in/opencms/resources/UploadCDSCOWeb/2018/UploadBloodBank/guidelines_for_blood_bank.pdf
2. *Common Cause v. Union of India*, (1996) 1 SCC 753 (SC, 4 Jan 1996) — https://indiankanoon.org/doc/1449517/
3. MoHFW, National Blood Transfusion Services (NBTC standards, TTI screening) — https://dghs.mohfw.gov.in/bts.php
4. *SC refuses to mandate NAT in all blood banks* (13 Mar 2026) — https://www.business-standard.com/india-news/sc-refuses-to-entertain-plea-seeking-mandatory-nat-in-all-blood-banks-126031300533_1.html
5. Department of Legal Affairs, *RTI Rules 2012 — fee and modes* — https://legalaffairs.gov.in/rti/fee-required-under-rti-act
6. Conditions of blood bank licence, Rule 122P (5-year record retention) — https://www.drugscontrol.org/pdf/cond_mfg_bloodbanks.pdf

Last reviewed: 3 July 2026.