Section 19(1). A person aggrieved by the PIO's decision may file First Appeal within 30 days of receipt of the PIO's decision, or the expiry of the 30-day reply window under Section 7(1) (deemed refusal).

Section 19(1) proviso. The FAA may admit a delayed appeal “if it is satisfied that the appellant was prevented by sufficient cause from filing the appeal in time”.

Section 19(4). Where appeal involves third-party information, the third party gets a reasonable opportunity to be heard.

Section 19(6). The appeal shall be disposed of within 30 days of receipt, or 45 days from the date of filing for reasons to be recorded in writing.

Section 19(3). Second Appeal to the Commission within 90 days of the FAA's decision or the date by which the decision should have been made.

• Clocks are independent. The PIO's delay does not extend the FAA's timeline.
• Fee restarts the PIO clock. Section 7(3) — if PIO asks for further fee, the 30-day clock starts afresh on payment. Relevant to appeal timing.
• Condonation is discretionary. The FAA may admit time-barred appeals; must record “sufficient cause”.
• 45-day extension requires reasons. Not automatic; the FAA must record why extension is needed.
• Second Appeal right accrues on deadline expiry. Even without a formal FAA order.

Appeal No. FA/2026/XXX

This First Appeal has been filed __ days beyond the 30-day period prescribed under Section 19(1) of the RTI Act, 2005. The Appellant has stated that the delay was occasioned by [state reason — medical emergency / postal delay / misdirected reply, etc.]. This Office is satisfied that sufficient cause has been shown.

In exercise of the proviso to Section 19(1), the delay is condoned and the appeal is admitted for consideration on merits.

This Office finds that the present appeal requires further examination of the PIO's file and a limited clarification from the third party notified under Section 11. In the interest of a reasoned disposal, the 30-day disposal window under Section 19(6) is extended by a further 15 days, so that disposal may be effected by DD-MM-YYYY.

The reasons for extension are recorded under Section 19(6) proviso: [state specific reason — third-party response awaited / complex multi-branch record / hearing scheduled, etc.].

• Silent extensions. Taking 45 days without recording reasons — non-compliance with the proviso.
• Treating the appellant's 30-day window as extendable by the FAA. It isn't unless the appellant pleads sufficient cause under §19(1).
• Missing the 30-day deadline without explanation. The Second Appeal right crystallises regardless.
• Charging fee for First Appeal. No fee is prescribed under the Act.
• Counting holidays incorrectly. Days are calendar days unless stated otherwise.

• Maintain an appeal calendar. Day 25 alert for pending appeals — gives you 5 days to act or record extension.
• Record condonation up-front. At the acknowledgment stage, not in the final order — simpler.
• Batch similar appeals. Disposal efficiency + consistency.
• Hear oral representations only where necessary — written disposal is faster and usually sufficient.

• CIC Full Bench (various) — §19(6) proviso requires recorded reasons; silent extensions invite Commission scrutiny.
• Bhagat Singh v. CIC (Delhi HC 2008) — timeliness is substantive; breach weakens the State's defence.
• Namit Sharma v. UoI (2013) — appellate procedure is quasi-judicial; written reasons are mandatory.

Q1. Can the appellant file First Appeal before the PIO's 30-day window expires?
Only if the PIO has issued a decision; otherwise premature. Deemed refusal crystallises on Day 31.

Q2. Does receiving the PIO's reply after filing the appeal affect the timeline?
No. The appeal proceeds on the reply that existed (or didn't) at filing date.

Q3. Can both parties agree to waive the 30-day disposal?
No. It's a statutory right, not contractual.

Q4. What if the FAA is absent?
The public authority must designate another senior officer to act as FAA. The deadline is institutional, not personal.

Q5. Does deemed refusal count as the PIO's “decision”?
Yes for appeal-filing purposes — the 30-day appellate window runs from the deemed-refusal date.

Two clocks, three timelines, one disciplined calendar. A FAA who keeps the appellate clocks clean issues timely speaking orders, preserves the Second Appeal escalation path, and protects the institution from Section 20 recommendations.

• FAA speaking-order guide
• Section 19(8) appellate powers
• FAA review checklist
• Deemed refusal (PIO side)
• PIO & FAA knowledge base

• RTI Act, 2005, Sections 7, 19
• Bhagat Singh v. CIC (Delhi HC 2008)
• Namit Sharma v. UoI (2013)

Last reviewed: 21 April 2026.