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cases:uoi-v-namit-sharma-review-2013-sc [2026/08/26 22:45] (current) – created - external edit 127.0.0.1
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 +{{htmlmetatags>metatag-keywords=(Union of India v. Namit Sharma (Review),Supreme Court of India RTI,RTI §12,RTI §15,RTI §16,Information Commission,review,Namit Sharma,bench composition)&metatag-description=(The review of Namit Sharma recalled the judicial-member reading: Commissions need judges neither as members nor on every bench — it is for Parliament to decide.)}}
 +
 +====== Union of India v. Namit Sharma (Review) ======
 +
 +
 +
 +{{ :social:auto:cases-uoi-v-namit-sharma-review-2013-sc.png?direct&1200 |Union of India v. Namit Sharma (Review) — RTI Wiki}}
 +
 +<WRAP center round info 95%>
 +**Quick Reply:** On review (3 September 2013), the Supreme Court **recalled the core of its own Namit Sharma directions**: Information Commissions are not required to include persons of judicial background as members, and benches need not be two-member with one judicial member — **it is for Parliament to legislate** such requirements. Commissioners already in office could continue. The result is the commission structure you see today.
 +</WRAP>
 +
 +<WRAP center round info 95%>
 +**Supreme Court of India** · 2013-09-03 · (2013) 10 SCC 359 · **★ Landmark**
 +</WRAP>
 +
 +
 +
 +**Review allowed in part: the judicial-member and two-member-bench directions of the principal judgment are recalled.**
 +
 +//The Commission works as the Act made it — Parliament's business, said the review, not the court's.//
 +
 +===== Case details =====
 +
 +^ Court | Supreme Court of India |
 +^ Decided | 2013-09-03 |
 +^ Citation | (2013) 10 SCC 359 |
 +^ Bench | A.K. Patnaik, Arjan Kumar Sikri |
 +^ Petitioner | Union of India |
 +^ Respondent | Namit Sharma |
 +^ RTI Act sections | §12, §15, §16 |
 +^ Outcome | Partly allowed |
 +
 +===== Outcome =====
 +
 +Review of Namit Sharma — two-member judicial-bench rule relaxed; Commissions allowed broader composition.
 +
 +===== What led here =====
 +
 +  * **13 September 2012** — *Namit Sharma v. Union of India*, (2013) 1 SCC 745: a two-judge bench read the Information Commissions as judicial tribunals and directed that they work in **benches of two, one member being of judicial background** ([[/cases/namit-sharma-v-uoi-2012-sc|case page]]).
 +  * The Union sought review; in **April 2013** an interim stay let sitting Chief Information Commissioners remain in office while the review was pending.
 +  * **3 September 2013** — this judgment, by the same bench (Patnaik and Sikri JJ.), confining itself to errors apparent on the record.
 +
 +===== What the review held =====
 +
 +  * The **judicial-qualification requirement is recalled** — the eligibility criteria in §§12(5) and 15(5) stand as enacted; reading judges-only into them was error.
 +  * The **two-member bench rule is relaxed** — Commissions may be constituted and hear matters in broader combinations.
 +  * **Separation-of-powers ground:** whether Commissions should have judicial members is a matter **for Parliament to decide**, not for the court to write into the statute.
 +  * **Sitting Commissioners continue** in office — the transition was not to unseat anyone.
 +
 +===== Why it matters =====
 +
 +  * It is the reason commissions today sit with combinations that include no judicial member, without objection.
 +  * It is a clean statement of the **review jurisdiction's limits** — even a wide reading of a statute cannot survive an error apparent on its face.
 +  * For the appointment debates that recur (vacancies, tenure after the 2019 amendment), the review is the anchor: the design question belongs to Parliament.
 +
 +===== Ratio decidendi =====
 +
 +The directions in the principal judgment requiring judicially qualified members and two-member benches are recalled; it is for Parliament to prescribe the composition of the Information Commissions.
 +
 +===== Keywords =====
 +
 +Information Commission, review, Namit Sharma, bench composition
 +
 +===== This case cites =====
 +
 +  * [[/cases/namit-sharma-v-uoi-2012-sc|Namit Sharma v. Union of India]] (SC 2012)
 +
 +===== Later rulings that cite this case =====
 +
 +  * [[/important-decisions/court/anjali-bhardwaj-vs-union-of-india|Anjali Bhardwaj v. Union of India]] (SC 2019)
 +
 +===== This ruling overruled / modified =====
 +
 +  * [[/cases/namit-sharma-v-uoi-2012-sc|Namit Sharma v. Union of India]] (SC 2012)
 +
 +===== Similar cases in the corpus =====
 +
 +//These rulings have the closest editorial ratio to this case — computed by tf-idf cosine similarity over ratio, keywords and Act sections. Useful starting points if you are researching the same point of law.//
 +
 +  * [[/cases/namit-sharma-v-uoi-2012-sc|Namit Sharma v. Union of India]] (SC 2012)
 +  * [[/cases/sc-natural-justice-rti-commission-hearing-2020|Natural justice in Information Commission hearings]] (SC 2020)
 +  * [[/cases/khanapuram-gandaiah-2010-sc|Khanapuram Gandaiah v. Administrative Officer]] (SC 2010)
 +  * [[/cases/cic-judicial-academies-2020|Judicial Academies under RTI — CIC]] (CIC 2020)
 +  * [[/cases/sc-rti-judicial-delay-information-2023|Judicial-delay records — SC]] (SC 2023)
 +
 +===== Related =====
 +
 +  * [[https://righttoinformation.wiki/cases/search?court=SC|All Supreme Court of India rulings in the corpus]]
 +  * [[https://righttoinformation.wiki/cases/search?section=12|All RTI cases turning on §12]]
 +  * [[https://righttoinformation.wiki/cases/search?section=15|All RTI cases turning on §15]]
 +  * [[https://righttoinformation.wiki/cases/search?section=16|All RTI cases turning on §16]]
 +  * [[https://righttoinformation.wiki/cases/search?landmark=1|All landmark rulings]]
 +  * [[:cases:search|Full case-law search]]
 +  * [[:cases|Case-Law Database — overview]]
 +  * [[:pio-rti-reply-guide|PIO RTI Reply Guide]]
 +  * [[:act|The RTI Act, 2005 — annotated]]
 +  * [[https://indiankanoon.org/doc/47938967/|External reported text →]]
 +  * [[/book|The RTI Playbook book]]
 +
 +===== FAQs =====
 +==== Did the review overrule Namit Sharma entirely? ====
 +No — it is a review, not an overruling: the directions on bench composition and judicial members were recalled; the characterisation of the Commission's function as quasi-judicial survived.
 +==== So can a single non-judicial member decide my second appeal? ====
 +Post-review, benches are not required to pair a judicial member; commissions have since functioned with varied compositions — your remedies run to the High Court under Article 226, not to the bench's shape.
 +==== What happened after? ====
 +The 2019 amendment and the RTI Rules, 2019 changed tenure and salaries; the composition question has remained with Parliament, as the review held — see [[:act:section-27|Section 27]] and [[:act:section-13|Section 13]].
 +
 +<WRAP center round alert 95%>
 +**Editorial summary, not a certified report.** The ratio here is an editorial compression. Before citing this ruling in a PIO order, FAA speaking order, or any appellate filing, **verify against the full reported decision**. RTI Wiki is not a legal service.
 +</WRAP>
 +
 +
 +
 +//Editorial summary · verified 27 August 2026 against indiankanoon.org/doc/47938967 (date, bench, holdings).//
 +
 +{{tag>case-law court-sc section-12 section-15 section-16 landmark}}