PIO File Noting Format for RTI Decisions

Every RTI reply is only as strong as the file noting that supports it. The First Appellate Authority and Information Commission read the noting before they read the reply. A defensible noting follows a fixed skeleton: dak diary, mapping of queries to documents, exemption analysis with case-law citation, severability and Section 11, costing and timeline, decision and signature. PIOs who skip this skeleton lose appeals routinely; those who follow it survive even contested cases.

When to use this guide

Use this guide every time an RTI request is opened. The format below is suitable for central ministries, state secretariats, public sector undertakings, banks, regulators and local bodies. It is consistent with the Manual of Office Procedure (MoP), the DoP&T RTI guidelines and CIC practice.

  • RTI Act 2005, the entire Act for substantive duties.
  • Manual of Office Procedure, chapters on dak, file opening and noting.
  • DoP&T Office Memorandum on RTI noting and disposal, periodically revised.
  • CIC and State Information Commission decisions on form and content of PIO orders.

The CIC has held in Vinod Kumar v MEA (CIC, 2014) and several later orders that a noting that does not record the Section 8 / Section 10 / Section 11 analysis is procedurally defective and may attract Section 20 penalty.

Step-by-step process

A PIO should follow this nine-step skeleton.

  1. Open a fresh RTI file. Number it as per the office's RTI register (eg “RTI/2026/Section/Serial”).
  2. Diary the dak. Receipt date and mode (post, courier, online), fee, details of the applicant.
  3. Number the points. Read the application; allocate a serial number to each query.
  4. Map queries to documents. For each point, list the file, register, register entry or website page that holds the information.
  5. Apply Section 8 / 9 / 10 / 11. For each point, record whether any exemption applies and why.
  6. Compute the fee under Section 7(3). Number of pages, mode of supply, intimation date.
  7. Address timeline. Record the 30-day deadline. If clarification or transfer was needed, note the dates.
  8. Decide and sign. Record the decision in clear language; sign with name, designation and date.
  9. Despatch. Reply by Speed Post AD or email; record the dispatch number in the noting.

Format / template

A complete file noting template. 

File no. RTI/[Year]/[Section]/[Serial]
Office of [Public Authority]

Subject: RTI application from [Applicant name] dated [DD/MM/YYYY]

PART A, DAK AND FACTS
1. Application received by [post / online / hand] on [DD/MM/YYYY] vide diary no. [number].
2. Fee: Rs [amount] paid by [IPO / online / DD]; confirmed deposited.
3. Applicant: [name], [address], [email if any].
4. Number of substantive queries: [number] (numbered Q1 to Q[n]).

PART B, QUERY-WISE MAPPING
For each query, the dealing assistant has recorded the following.

Q1: [Reproduce the query]
Documents that respond: [List]
Held by: [Section / register / officer]
Exempt? [No / Section 8(1)(_) / Section 9 / Partly]
Reasons: [Brief reasoning]
Decision: [Disclose / Decline / Disclose in part]

Q2: [Reproduce the query]
Documents: [List]
Exempt? [....]
Section 11 trigger: [Yes / No]; if yes, third party identified as [name]; notice issued on [date]; representation received on [date]; hearing held on [date]; reasons recorded.
Severability under Section 10: [Yes, paragraphs X and Y disclosed; A and B redacted / No].
Decision: [....]

[Repeat for each query]

PART C, EXEMPTION ANALYSIS
1. For Q[number]: Section 8(1)(j) two-limb test applied; Girish Ramchandra Deshpande v CIC (2013) 1 SCC 212 followed. Public-interest override considered and [accepted / rejected] for the reasons recorded.
2. For Q[number]: Section 8(1)(d) commercial confidence; Section 11 followed; severance under Section 10 applied.
3. For Q[number]: Section 9, copyright owned by a non-government party; alternative summary supplied.

PART D, TIMELINE
1. Day 0: receipt on [date].
2. Day 5: Section 11(1) notice issued on [date].
3. Day 15: representation received on [date].
4. Day 25: hearing held on [date].
5. Day 30: reply prepared by [date]; despatched on [date].

PART E, FEE
1. Section 7(3) intimation issued on [date] for Rs [amount] (Rs 2 per A4 page x [number] pages).
2. Payment received on [date]; remaining [pages] dispatched on [date].

PART F, DECISION
1. Information at Q1, Q3, Q5 is disclosed in full.
2. Information at Q2 is disclosed in part with redaction of [reference] under Section 8(1)(j) read with Section 10.
3. Information at Q4 is declined under Section 8(1)(g) for the reasons recorded.
4. Applicant is informed of the right of First Appeal under Section 19(1); third party at Q2 is informed of the right under Section 11(4) read with Section 19(2).

[Signature]
[PIO Name]
[Designation]
[Office, Telephone, Email]
[Date]

PART G, DESPATCH
1. Reply despatched by Speed Post AD on [date], AD no. [number].
2. Reply also sent by email to [address] on [date], delivery confirmed.
3. File closed; appeal window monitored.

Common mistakes

  • No dak diary. A noting that does not show the receipt date is unusable in appeal.
  • Generic exemption. “Section 8(1)(j), denied” without reasoning is reversed.
  • No Section 10 paragraph. Even when full disclosure is decided, record that severance was considered and not needed.
  • No Section 11 paragraph. When third-party data is involved, the noting must mention the trigger consideration (yes/no, with reasons).
  • No timeline log. When First Appeal alleges delay, the timeline log is your defence.
  • No costing log. Section 7(3) fee intimation date and payment date must be recorded.
  • Generic signature line. Always include name, designation and date. Stamp alone is not enough.

Appeal or next step

  • First Appeal under Section 19(1), the FAA reads this noting before any reply.
  • Second Appeal to CIC / SIC, the noting is the document the Bench evaluates.
  • Section 20 penalty when noting is missing or contradictory.
  • Internal RTI register must show every file from receipt to closure.

FAQs

Is the noting itself disclosable to the applicant?

Yes, in most cases. The substantive noting on the RTI request becomes part of the file. The DoP&T has clarified that file notings are not exempt by virtue of being notings.

Yes. The PIO can consult the law cell or the dealing officer's superior, but the decision is the PIO's.

What if the dealing assistant resists giving the documents?

The PIO has authority under Section 5(4) to seek assistance; refusal can be reported.

Should the noting be in English or the official language of the area?

Either, consistent with the office's working language. Where the applicant has used a different language, the reply at minimum should be in the language of the application.

Should the noting reproduce the application?

A summary of each query is enough; the full application is on file.

Can the PIO redact the noting on appeal?

The PIO is not the appellate authority. The FAA may direct redaction or further disclosure.

What if the file is electronic?

The same skeleton applies; record dates, decisions and exemption analysis on the e-noting screen and export a PDF for the file.

Sources

Last reviewed: 9 May 2026.

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