First Appellate Authority in RTI — citizen guide 2026

The First Appellate Authority, usually called the FAA, is the officer in the same public authority who is senior in rank to the CPIO or SPIO and hears the first appeal under section 19(1) of the Right to Information Act, 2005. You approach the FAA when the PIO's decision is late, absent, incomplete, wrongly exempted or otherwise adverse.

The RTI Act creates an internal two-officer structure:

• CPIO/SPIO: receives and decides the information request at the first stage;
• FAA: reviews the PIO's decision or failure at the first-appeal stage;
• CIC/SIC: hears the later second appeal for Central or State public authorities, respectively.

The FAA is not an Information Commissioner and is not outside the department. The FAA is an officer senior in rank to the PIO within that public authority. The role is statutory, however: an FAA should decide the grounds of appeal rather than merely forward the paper back to the same PIO without an order.

Section 19(1) covers two broad triggers: no decision within the period in section 7, or an applicant who is aggrieved by the PIO's decision. Common grounds are:

• no reply by the applicable deadline;
• partial reply without identifying what was withheld;
• an exemption cited without applying it to the requested record;
• refusal to sever exempt material and provide the remainder under section 10;
• information supplied in a different or unusable form without a lawful reason;
• unreasonable further-fee calculation;
• no access for inspection or certified copy despite the record being held;
• missing appellate-authority particulars in an adverse reply;
• a transfer or “not held” response that does not answer record custody.

A service complaint—“approve my pension” or “repair my road”—is not transformed into an RTI appeal. Ask the FAA for access to records under the Act, not an order deciding the underlying grievance.

The normal RTI reply period is 30 days, but life-or-liberty, APIO and third-party situations can change the response calculation. Use the Timeline Tracker as an aid, then verify the receipt date and the Act.

Do not wait indefinitely for a reminder reply. Preserve the appeal clock while correspondence continues.

Section 7(8)(iii) requires a rejection decision to communicate particulars of the appellate authority. Also check:

• the PIO reply footer;
• the public authority's RTI or section 4 disclosure page;
• the RTI Online record for participating Central authorities;
• the department directory or RTI manual;
• the receipt/portal entry for the original application.

The FAA must belong to the same public authority as the PIO whose decision is challenged. Do not address a first appeal to the CIC, a Minister or the district grievance officer.

If the reply names no FAA, mention that omission as a ground. Address the appeal by designation if the officer's name may have changed.

Build a short, chronological set:

1. first appeal with date and signature;
2. copy of the original RTI application;
3. filing/payment/delivery proof;
4. PIO reply and enclosures, if any;
5. further-fee notice and payment, if relevant;
6. one table matching each request item to the answer received;
7. specific official rule or record-form evidence relied on;
8. proof of sufficient cause if the appeal is late.

Do not attach an unindexed dump of unrelated complaints. The FAA needs to see the RTI question, the PIO action and the error.

To: The First Appellate Authority, [public authority]
Subject: First appeal under section 19(1), RTI Act, 2005

RTI reference/date: [details]
PIO reply/date: [details, or "no decision received"]

Ground 1: Item 1 requested [record]. The reply [quote briefly] does not
provide or deny that record and identifies no exemption.

Ground 2: Item 2 was denied under section [clause], but the reply does not
apply the clause to the record or consider severance under section 10.

Relief requested:
1. decide each ground by a reasoned order;
2. direct access to the identified records in the requested available form;
3. provide any delayed information free under section 7(6);
4. provide severable non-exempt portions under section 10; and
5. communicate the order and compliance action to me.

Attachments: indexed A1 to A[number]
Name, address, date and signature

Use the First Appeal Builder to structure the draft. Check every date, section and authority yourself.

In the first appeal, the FAA can examine whether the PIO handled the request according to the Act and decide the access dispute. A useful order addresses each request item and ground, states the exemption or disclosure conclusion, deals with severability and fees, and identifies compliance.

Section 19(5) places the onus of proving that denial was justified on the PIO in appeal proceedings. The applicant should still make the factual gap clear; the burden rule is not a reason to file a blank appeal.

The FAA does not exercise the Information Commission's section 20 penalty power. A first appeal should not promise a ₹25,000 penalty or compensation. The Commission later decides its statutory powers on the record and after due process.

RTI Online's official FAQ says no fee is payable for a first appeal under the Central online route. State public authorities follow their own notified rules and filing systems; some State rules may prescribe a fee or a different method.

Never send a guessed ₹10 Indian Postal Order for every first appeal. Check the relevant Central or State rule and the public authority's official instructions. Preserve any payment proof.

Read the order against your grounds. An adverse order is not automatically invalid merely because the FAA agrees with the PIO, but an order that ignores items, gives no exemption analysis or fails to address severability can be challenged in second appeal.

Section 19(3) gives a 90-day period for second appeal from the date the FAA decision should have been made or was actually received. Choose CIC for covered Central public authorities and the appropriate SIC for State public authorities. See the second-appeal filing guide.

Keep proof that the first appeal reached the FAA. Without it, the Commission may treat a later second appeal as premature or deficient.

• Sending the “first appeal” back to the same PIO without addressing the FAA.
• Filing directly with CIC/SIC before completing section 19(1).
• Asking for grievance relief instead of information access.
• Rewriting the RTI with new requests at appeal stage.
• Saying only “reply is unsatisfactory” without item-by-item grounds.
• Missing a State-prescribed fee or using a Central fee assumption.
• Waiting beyond the second-appeal clock for repeated reminders.
• Asking the FAA to impose the section 20 statutory penalty.

The Act describes the appellate officer as senior in rank to the CPIO/SPIO in the same public authority. The precise administrative reporting line can vary.

No. It is an internal first appeal within the same public authority, but the duty to decide comes from section 19 of the RTI Act.

Thirty days, extendable to a total of 45 days in exceptional cases with reasons recorded in writing.

The Central RTI Online route states no fee. Check the notified rules for the relevant State public authority rather than assuming.

Yes. Expiry of the applicable section 7 decision period is a first-appeal trigger under section 19(1).

No. Section 20 assigns the statutory penalty decision to the Information Commission, not the FAA.

The appeal reviews the original request and PIO decision. File a separate RTI for genuinely new records.

Preserve filing proof and use the second appeal to the correct CIC/SIC within the section 19(3) period calculated from when the decision should have been made.

Correct public authority; FAA designation; RTI; receipt; PIO reply; response deadline; appeal deadline; item-by-item grounds; section 10; section 7(6); attachments index; State/Central fee check; delivery proof; FAA order; compliance; and second-appeal date.

• RTI Wiki home
• Second appeal to CIC or SIC
• RTI Act explained simply
• Track an RTI appeal safely
• First Appeal Builder
• Timeline Tracker
• PIO Reply Checker

• DoPT — Right to Information Act and amended official text
• DoPT — official RTI portal and appellate-authority resources
• RTI Online — first-appeal filing and fee FAQ
• RTI Online — first-appeal portal guidelines
• Central Information Commission — appeal FAQ