Table of Contents
Module 02 — §4 suo-motu disclosure compliance audit
What §4(1)(b) requires
17 categories every public authority MUST publish suo motu (without an RTI request):
- (i) particulars of organisation
- (ii) powers + duties of officers + employees
- (iii) decision-making procedure
- (iv) norms for discharge of functions
- (v) rules + regulations + manuals
- (vi) categories of documents held
- (vii) particulars of consultative bodies
- (viii) directories of officers
- (ix) salary scales
- (x) budget
- (xi) subsidy programmes
- (xii) beneficiary lists [killer one]
- (xiii) concessions, permits granted
- (xiv) electronic records held
- (xv) facilities for citizen info
- (xvi) PIO names
- (xvii) any other
§4(1)(b)(xii) — the beneficiary list
Every public authority must publish lists of beneficiaries of programmes it administers. Almost no authority complies. That non-compliance is itself the story.
Campaign template:
- File 1-question RTI: “Provide the §4(1)(b)(xii) beneficiary list for [scheme] for FY [year], as required by the RTI Act.”
- PIO can't refuse — it's a mandatory disclosure.
- PIO either provides (publishable) or refuses (which is itself a §20 penalty motion).
Compliance audit framework
Build a §4 compliance scorecard for any authority:
- Visit the authority's website.
- For each of the 17 §4(1)(b) categories, mark: published / partial / missing / outdated.
- Score out of 17.
- Cross-link RTI for what's missing.
NGO Centre for Civil Society + Transparent Chennai have done this for ULBs — typical score is 6-8/17.
CIC complaints under §18
Distinct from §19 appeals — §18 is a complaint to the CIC/SIC about systemic non-compliance with §4 (or §6, §7). No fee. No 30-day limit.
Use §18 when:
- Authority repeatedly fails to publish §4 disclosures
- PIO is unidentifiable
- There's no decision to appeal (because there's no acknowledged application)
§18 can result in CIC penalty under §20 against the authority's chief.
Public-interest petition follow-up
After CIC issues directions on §4 non-compliance, file a PIL in the relevant HC if compliance still doesn't follow. Major precedent: *DAV College Trust v. Director of Public Instructions* — schools must publish under §4 even though they're aided NGOs.
✅ Quiz
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Last reviewed: 24 April 2026.

