A practitioner summary of the Satark Nagrik Sangathan assessment released on the twentieth anniversary of the Right to Information Act, 2005, with implications for applicants, officers, and Commissions.

On 12 October 2025, the Right to Information Act, 2005 completed twenty years of operation. The Act was assented to on 15 June 2005 and came into force on 12 October 2005. It repealed and replaced the Freedom of Information Act, 2002.

On the occasion of the twentieth anniversary, Satark Nagrik Sangathan, a civil society organisation that has tracked the functioning of the Information Commissions from 2006 onward, released its annual assessment. The assessment covers the performance of the Central Information Commission and the State Information Commissions between 1 July 2024 and 30 June 2025.

The findings are summarised below for reference by practitioners.

On 30 June 2025, the total number of appeals and complaints pending before twenty-nine Information Commissions stood at more than four lakh cases.

The State Information Commissions with the highest pendency are listed in the table below.

Telangana, at the rate of disposal recorded during the year, would take approximately twenty-nine years to clear its backlog on the present caseload.

During the year 1 July 2024 to 30 June 2025, twenty-seven Commissions disposed of approximately 1.8 lakh cases. The disposal rate has fallen in relation to the rate recorded in the earlier year, which indicates a worsening of the pendency-to-disposal ratio.

Among the State Commissions, the highest disposal figures for the year were reported by:

Section 20 of the Right to Information Act, 2005 empowers the Commission to impose a penalty of up to twenty-five thousand rupees on a Public Information Officer who, without reasonable cause, refuses to receive an application, does not furnish information within the time specified, malafidely denies a request, knowingly gives incorrect or incomplete information, destroys information, or obstructs the furnishing of information.

The assessment records that in approximately ninety-eight per cent of cases in which a penalty was eligible to be imposed, no penalty was imposed. The imposition of penalty has remained the exception rather than the rule across successive years of assessment.

The consequence is a weakening of the deterrent that Section 20 was intended to create. Public Information Officers who delay or deny information face limited risk of a personal financial liability, though adverse observations in the order of the Commission continue to be recorded and communicated to the parent authority.

The assessment records that of all persons appointed as Information Commissioners in the Central Information Commission and State Information Commissions from 2005 onward, approximately nine per cent have been women. The figure is considered low in relation to the representation of women in other statutory appointments and reflects a composition that has not changed appreciably across successive appointments.

Section 25 of the Right to Information Act, 2005 requires each Commission to prepare an annual report on the implementation of the Act during the year, and to forward the report to the appropriate Government. The report is required to be laid before each House of Parliament or the State Legislature as the case may be.

The assessment records that twenty of twenty-nine Commissions had not published an annual report for 2023-24 at the time of the assessment. The failure to publish the annual report is a departure from a statutory obligation and impairs the Parliamentary and Legislative oversight of the working of the Act.

A related finding is that a number of Commissions do not place basic information on their own websites in the manner required of other public authorities under Section 4. The information that is not uniformly available includes:

1. the date of filing of each second appeal and complaint;
2. the stage of each case;
3. the next date of listing;
4. the orders passed by each bench, classified and searchable.

The position improved in Commissions that have modernised their case management. The assessment notes that Telangana's case management portal has reduced average processing time by a significant margin, and suggests that other Commissions consider a similar investment.

• Applicants should file second appeals with a complete set of enclosures and clearly numbered grounds. Appeals with gaps are more likely to be adjourned.
• Where an application has remained unanswered beyond thirty days, a first appeal should be filed without waiting for a reply. The clock for the second appeal runs from the date of decision of the first appeal or the expiry of the period for such decision.
• Where a Commission is known to have long pendency, the grounds in the second appeal should be drafted with the Commission's likely written disposal in view. A clear, numbered set of grounds allows a written order to be passed without repeated listings.

• The continued low rate of penalty imposition should not be read as an absence of accountability. Orders of the Commission are recorded in the service record of the Officer and form part of the institutional reputation of the public authority.
• Replies should address every limb of the application separately. A composite reply that does not address each limb is the single most common ground on which adverse observations are recorded.

• The publication of the annual report under Section 25 is not a discretionary matter. It is recommended that each Commission place the latest annual report on its website within three months of the close of the year.
• Case management portals that permit real-time filing, tracking, and order retrieval are associated with higher disposal rates.

Several reform proposals have been raised in academic and policy literature and have been considered by Parliamentary Committees in earlier years. The proposals that continue to be raised include:

1. Filling of vacancies in the Central Information Commission and State Information Commissions one to two months before the date on which the vacancy is expected to arise, in line with the directions of the Supreme Court in Anjali Bhardwaj v. Union of India.
2. Appointment of Information Commissioners from backgrounds beyond retired civil service, including from law, journalism, and academia, in line with the fields of eminence listed in Section 12(5).
3. A statutory time-limit for disposal of a second appeal from the date of its filing.
4. Restoration of the fixed tenure and salary framework for Information Commissioners that was in effect before the Right to Information (Amendment) Act, 2019.
5. A review of the amendment to Section 8(1)(j) effected by Section 44(3) of the Digital Personal Data Protection Act, 2023, to restore the public interest override that had operated through the earlier text of the clause.

• Satark Nagrik Sangathan, Report Card of Information Commissions in India, 2024-25 (October 2025).
• The Right to Information Act, 2005 (Act 22 of 2005), Sections 4, 12, 20, and 25.
• Anjali Bhardwaj v. Union of India (2019) 10 SCC 1.
• The Right to Information (Amendment) Act, 2019.
• Central Information Commission, Annual Report 2023-24.

19 April 2026

• Raj Kumar Goyal sworn in as Chief Information Commissioner; CIC reaches full strength.
• Live tracker.
• DPDP Rules, 2025: The amendment to Section 8(1)(j) of the RTI Act.

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