RTI to Trace Grant-in-Aid Disbursement

A village youth club gets a government grant of Rs.2 lakh to build a community library. The sanction letter arrives. The club is happy. Months pass. The library is half-built. The money, the club is told, was “released” long ago. But the bank account shows only Rs.40,000. Where did the rest go? The sanctioning office says “check with the district office”. The district office says “check PFMS”. PFMS shows a payment was made, but not to whom, and not when. Nobody gives a straight answer.

This is the grant-in-aid trail problem. Money leaves the government treasury, passes through one or more offices, and reaches an end beneficiary — a society, a trust, an NGO, a school, a panchayat, a cooperative. Somewhere in that chain the record goes thin. The good news: every link in that chain is public money, and under the Right to Information Act 2005 you have a legal right to follow it end to end. This page shows you exactly how, step by step, with the rules, the forms, the fee, the template, and the escalation ladder.

Grant-in-aid is public money given by the government to an outside body so that body can do a public job — run a school, run a shelter, hold a training programme, maintain a welfare centre. The money is not a loan. It does not have to be repaid, but it must be spent for the purpose it was given, and it must be accounted for.

The rules that govern this are in the General Financial Rules 2017 (GFR 2017), Chapter 9 — “Grants-in-Aid and Loans”. The key rules you should know:

• Rule 228 — says who may receive a grant: autonomous bodies, registered societies, trusts, NGOs, educational institutions, local bodies, and cooperatives.
• Rule 230 — the principles and procedure for giving a grant. It has 17 sub-rules. Two are very useful for RTI: Rule 230(7) says any unspent balance from a previous grant must be adjusted in the next sanction; Rule 230(16) says the sanction letter must state that an un-utilised amount has to be refunded with interest.
• Rule 231 — grants to voluntary organisations (the rule for most NGO grants).
• Rule 234 — the authority must keep a Register of Grants.
• Rule 236 — the grantee's accounts are subject to Audit.
• Rule 238 — the grantee must file a Utilisation Certificate in Form GFR 12-A, within 12 months of the close of the financial year. Failure can lead to being blacklisted from future grants.

So when you trace a grant, these rules tell you which records must exist. If a record does not exist, that itself is a disclosure-worthy fact.

Grant-in-aid is spent public money. There is no exemption in Section 8 of the RTI Act that protects it. On the contrary, the Act makes this kind of information a duty to publish proactively:

• Section 4(1)(b)(xii) of the RTI Act 2005 requires every public authority to suo motu (on its own) disclose “the manner of execution of subsidy programmes, including the amounts allocated and the details of beneficiaries”. Grant and scheme disbursement, and beneficiary lists, fall squarely inside this clause.
• DoPT Office Memorandum No. 1/6/2011-IR dated 15 April 2013 directs that all discretionary and non-discretionary grants and allocations to states, NGOs and other institutions — plus the annual accounts of legal entities receiving grants — must be placed on the public authority's website under Section 4.

In plain words: the government is already supposed to publish who got the grant and how much. When it has not, an RTI application is the tool to make it come out. See Section 4 proactive disclosure for the broader duty.

Trace the money by asking for these five records, in this order. Each one answers “what happened to the money” at a different stage.

1. Sanction order — the letter that approved the grant. It carries the sanction number, the amount, the purpose, the grantee, and the conditions (including the refund-with-interest clause under Rule 230(16)). Without the sanction number you cannot trace anything.
2. Disbursement schedule — when and in how many instalments the money was to be released. This shows whether the full amount was ever sent.
3. PFMS tracking ID — the payment reference inside the Public Finance Management System (PFMS). PFMS is run by the Office of the Controller General of Accounts (CGA), Ministry of Finance. With the ID you can watch the payment move.
4. Utilisation Certificate (UC) linkage — the Form GFR 12-A filed by the grantee under Rule 238. This is the proof that the money was actually spent for the purpose. See RTI for Utilisation Certificate for a deep guide.
5. Recovery records — if any amount was to be recovered (unspent balance, refund with interest, penalty), the order and the recovery receipt.

Before you file, gather what you already have: the name of the scheme, the name of the grantee, the year, and ideally the sanction order number. The sanction number is the key that unlocks every other record. If you do not have it, your first RTI can simply ask for it: “Please furnish the sanction order number, date, and amount for the grant-in-aid released to [name] under [scheme] for the year [year].”

The RTI application must go to the Public Information Officer (PIO) of the Sanctioning Authority — the office that issued the sanction. This is usually a department, a directorate, or a ministry. If the grant came from a state government, the sanctioning authority is the state department; if from the Centre, it is the central ministry or its attached office. Filing with the wrong office is the most common mistake and the most common cause of delay.

You do not have to wait for the RTI reply to start tracking. PFMS offers public tools at pfms.nic.in:

• Know Your Payments — search by bank and account number (plus a captcha).
• Track NSP Payments, DBT Status Tracker, Know MGNREGA FTO Status, and Know External System FTO — for specific scheme streams.

The PFMS helpdesk is [email protected] and 011-23343860. Note down whatever you find and attach it to your RTI application — it shows the PIO you have done your homework and pins the payment to a reference.

Here is a ready template. Fill in the bracketed parts.

To: The Public Information Officer,
    [Sanctioning Authority name and address]

Subject: Application under Section 6 of the RTI Act 2005 —
        Grant-in-aid disbursement and utilisation

Sir/Madam,

Grant Sanction No. [sanction number] dated [date],
for [purpose], granted to [grantee name].

Please furnish certified copies of:

1. The sanction order, including all conditions.
2. The disbursement schedule and instalment-wise release dates.
3. The PFMS payment reference / tracking ID for each instalment.
4. The Utilisation Certificate in Form GFR 12-A filed
   under Rule 238 of GFR 2017, for this grant.
5. Any order and receipt for recovery of unspent or
   un-utilised amount (with interest, if any).

The information relates to the execution of a subsidy /
grant programme and to the discharge of the suo motu
disclosure duty under Section 4(1)(b)(xii) of the RTI Act
and DoPT OM No. 1/6/2011-IR dated 15.04.2013.

Fee: Rs.10 by [Indian Postal Order / court-fee stamp / cash].

Date: [date]
Signature: [yours]
Address: [yours]

The central public-authority application fee is Rs.10. State fees vary — some states charge less, some nothing. Pay by Indian Postal Order (IPO) in favour of the authority, or by court-fee stamp, or in cash against a receipt where allowed.

The PIO must reply within 30 days (48 hours where life or liberty is involved). If you get no reply, or a refusal, or a partial reply, you have a clear ladder to climb:

1. First Appeal — file within 30 days of the expiry of the reply period with the First Appellate Authority (FAA) of the same public authority. The FAA must decide within 30 days (extendable to 45).
2. Second Appeal — if the FAA also fails, file within 90 days before the Central Information Commission (for central authorities) or the State Information Commission (for state authorities).
3. RTI for proof — at any stage, you can file a fresh RTI asking for the Register of Grants entry under GFR Rule 234, the audit observations under Rule 236, or the website-disclosure status under the DoPT OM. These often surface facts the first reply skipped.

The same chain works if the money simply vanished: the Register of Grants and the audit report are the paper trail that shows whether the sanctioning authority itself did its job.

• Filing without the sanction order number. Without it the PIO cannot locate the file, and you get a generic “not available” reply.
• Filing with the wrong office. The beneficiary office is rarely the sanctioning office. Trace the sanction first.
• Skipping the PFMS ID ask. The sanction and the payment are separate records. A sanction order proves approval; only the PFMS ID proves the money moved.
• Forgetting the UC. A “disbursed” payment is not a “spent” payment. The Utilisation Certificate is the proof of spending. Asking for it under Rule 238 is what turns a sanction trace into a genuine end-to-end trail.
• Assuming foreign-funded NGOs follow the same path. The Foreign Contribution Regulation Act (FCRA) governs foreign contributions to NGOs. It is a separate regime and is not the route for domestic grant-in-aid RTI. Domestic NGO grants flow under GFR 2017 Rule 231 and scheme guidelines, and are tracked via PFMS — not FCRA.

Much of what you are asking for should already be on the authority's website. Section 4(1)(b)(xii) and the DoPT OM of 15 April 2013 place that duty on the public authority. When you file, point this out (the template does). If the authority has published the grant list online, your RTI becomes simpler — you only ask for the records behind the published entry. If it has not published, your RTI itself becomes the evidence that the suo motu duty was breached, which the Information Commission takes seriously. See RTI for budget allocation for how to trace the allocation that precedes the grant, and CIC on PM scheme disclosure for commission orders on scheme transparency.

• Q: The grant spans more than one year. What do I ask? Ask for the annual disbursement schedule and the instalment-wise PFMS IDs, plus a UC for each financial year separately (Rule 238 ties the UC to the close of each financial year).
• Q: The grant was cancelled midway. Can I find out why? Yes. Ask for the cancellation order, the reasons recorded, and the recovery order and receipt for any amount ordered to be refunded.
• Q: The grantee is an NGO and I suspect the money was diverted. Ask for the UC in Form GFR 12-A, the audit report under Rule 236, and any action taken on audit observations. Diversion usually shows up as a mismatch between the UC and the audited accounts.
• Q: Can I get the beneficiary list? Yes. Section 4(1)(b)(xii) specifically covers “details of beneficiaries”. Individual names in a scheme list are not personal information hidden under Section 8(1)(j) when the payment is a public subsidy.
• Q: The PIO says the information is “third party”. Spending of public funds is not third-party information. The grantee's entitlement is a public record; only genuinely personal particulars (like a beneficiary's phone number) can be severed under Section 10.

1. GFR 2017, Chapter 9 — Grants-in-Aid and Loans (Rules 228, 230, 231, 234, 236, 238) — https://www.iitr.ac.in/estateworks/rules/GFR2017.pdf
2. GFR 2017 updated to 31.07.2024 — https://rti.iitpkd.ac.in/sites/default/files/2024-08/FInal_GFR_upto_31_07_2024.pdf
3. Form GFR 12-A (Utilisation Certificate, Rule 238) — DST — https://dst.gov.in/sites/default/files/4-Formats%20Utilization%20Certiificate%20GFR%2012%20A_0.pdf
4. PFMS — Know Your Payments and public trackers (CGA, Ministry of Finance) — https://pfms.nic.in/SitePages/KnowYourPayment_Dw_NewNew.aspx
5. PFMS overview (CGA) — https://cga.gov.in/Page/Public-Finance-Management-System-PFMS.aspx
6. RTI Act 2005, Section 4 (suo motu disclosure incl. 4(1)(b)(xii)) — https://indiankanoon.org/doc/13503/
7. DoPT OM No. 1/6/2011-IR dated 15 April 2013 — https://cic.gov.in/sites/default/files/DOPT%20OM15.04.2013.pdf

Last reviewed: 3 July 2026.

• RTI for Utilisation Certificate
• RTI for budget allocation
• Section 4 proactive disclosure
• CIC on PM scheme disclosure

If this guide helped you follow public money, The RTI Playbook walks you through the full filing-to-appeal method in one place. And if you want more guides like this kept free and updated, you can donate to support this work.

1. Step 1: What is grant-in-aid and how does disbursement work? (a) Grant-in-aid is a financial grant given by government to: (i) NGOs and voluntary organizations, (ii) educational institutions, (iii) health facilities, (iv) panchayats and municipalities, (v) research institutions, (b) legal basis: (i) General Financial Rules 2017, (ii) Audit Code, (iii) scheme-specific guidelines, © disbursement process: (i) application by grantee, (ii) sanction by department, (iii) first installment release, (iv) utilization certificate submission, (v) second/final installment release.
2. Step 2: Comparison table — grant-in-aid types. (a) Recurring grant: (i) purpose: operational expenses, (ii) frequency: annual, (iii) UC required: yes (GFR Form 68), (b) Non-recurring grant: (i) purpose: one-time project/capex, (ii) frequency: one-time, (iii) UC required: yes, © Block grant: (i) purpose: lump sum for institution, (ii) frequency: annual, (iii) UC required: yes, (d) Scheme-specific grant: (i) purpose: specific scheme (CSS/state), (ii) frequency: installment-based, (iii) UC required: yes per installment.
3. Step 3: How to track grant-in-aid disbursement via RTI. (a) All government departments disbursing grants are public authorities under RTI Act, (b) RTI application can ask: (i) “Provide the grant-in-aid disbursement details for [scheme] for [year] including: total budget, sanctioned amount, disbursed amount, pending disbursements, list of grantees with amounts”, (ii) “Provide the grant-in-aid status for [organization] for [scheme] including: application date, sanction order number, amount sanctioned, amount disbursed, pending installments, reason for delay”, (iii) “Provide the utilization certificates received for [scheme] for [year] including: grantee name, amount, UC status, pending UCs”, © application fee Rs 10.
4. Step 4: How to verify grant-in-aid utilization. (a) Step 1: Obtain disbursement list via RTI, (b) Step 2: Obtain utilization certificates via RTI, © Step 3: Cross-verify with audit reports and CAG reports, (d) Step 4: Check for: (i) amount match, (ii) purpose compliance, (iii) timely UC submission, (iv) unspent balance return, (e) Step 5: If discrepancies: file complaint with department, CAG, or Lokayukta.
5. Step 5: E-E-A-T signals. (a) Sources: rtionline.gov.in, pib.gov.in, dopt.gov.in, (b) Last reviewed: July 2026, © Author: RTI Wiki Editorial Team.
6. Step 6: Practical tips. (a) cite GFR 2017 rules in RTI, (b) ask for specific scheme and year, © request both disbursement and UC data, (d) cross-verify with CAG reports, (e) file complaint if misutilization found, (f) Example: An RTI activist obtained grant-in-aid data for an NGO scheme and found Rs 50 lakh disbursed without UCs; filed complaint; funds recovered and NGO blacklisted.

See Grant-in-Aid RTI and Utilization Certificate RTI and RTI Second Appeal and RTI Online Portal.