How PIO Should Handle Vague, Voluminous or Multi-Subject RTI Applications
A vague or voluminous RTI is not an excuse for refusal. The RTI Act 2005 gives a PIO four legitimate tools: Section 7(9) (form in which information is provided), Section 2(j) (right to inspect), Section 6(3) (transfer to right office) and Section 7(3) (further fee on cost intimation). PIOs who reject vague RTIs without using these tools regularly lose appeals and face Section 20 penalty. The right approach is to engage with the applicant, narrow the scope, offer inspection, transfer multi-subject limbs, and produce what is reasonably possible.
When to use this guide
Use this guide when an RTI request is (a) vague (eg “send all information about my case”); (b) voluminous (eg “all noting on every file in your section for the last 10 years”); © multi-subject (eg one application asking for records held in 8 different ministries); (d) in a different language or script than your office uses; (e) without a fee or with an inadequate fee; (f) addressed to your office but the records are held by another public authority.
Legal basis
- RTI Act 2005, Section 2(j): right to information includes the right to inspect work, documents and records and to take notes, extracts or certified copies.
- Section 6(1) and 6(3): format of application; transfer to the right public authority within five days.
- Section 7(1): 30-day reply.
- Section 7(3): further fee on cost intimation; the time between intimation and payment is excluded from the 30-day clock.
- Section 7(9): information shall be provided in the form sought, unless it would disproportionately divert the resources of the public authority or be detrimental to the safety or preservation of the record.
- Section 7(2): deemed refusal at end of 30 days, with consequences.
The CIC has held in Sumati Singh v MCD (CIC, 2007), Anand Saxena v MEA (CIC, 2018) and several follow-on decisions that vague or voluminous RTIs cannot be summarily rejected; the PIO must use Section 7(9) and Section 2(j) creatively.
Step-by-step process
A PIO faced with a difficult RTI should follow this sequence.
- Read the application carefully. Try to identify each query as a distinct point. Number them in your working sheet.
- Group queries by subject and by office. If multiple offices hold the records, use Section 6(3) to transfer the relevant queries within five days.
- For vague queries, write to the applicant. Under DoP&T guidance, a PIO may seek clarification within five days of receipt; the time between the clarification request and the applicant's reply is generally excluded from the 30-day clock per CIC practice. Do this in writing with reasons.
- For voluminous queries, invoke Section 7(9). Do not refuse, instead inform the applicant that providing all the records in the form sought would disproportionately divert the resources of the public authority, and offer (a) inspection under Section 2(j) at a fixed date and time, (b) further fee intimation under Section 7(3) for the certified copies, and © a representative sample.
- For mixed exempt + non-exempt records, apply Section 10 severability.
- Document everything. Each step in the file noting; each communication by Speed Post AD or tracked email.
- Decide within 30 days (excluding properly recorded clarification time).
Format / template
Sample reply for a vague request.
Sub: Your RTI application dated [DD/MM/YYYY] under Section 6 of the RTI Act, 2005 Sir / Madam, Your application has been received in this office on [date]. To enable a complete and timely reply, the queries at point [number(s)] need clarification, as they presently do not specify the scope (period, subject, file reference). I request you to: 1. Specify the period for which the information is sought. 2. Identify the subject or file reference, where known. 3. Indicate the form of supply (certified copy / inspection / electronic). Time taken in this clarification will be governed by the relevant CIC guidance and the principle of fairness. The 30-day clock will resume on receipt of your clarification. Yours faithfully, [PIO]
Sample reply for a voluminous request.
Sub: Your RTI application dated [DD/MM/YYYY] Sir / Madam, The information requested at point [number] requires retrieval and certification of approximately [number] pages spread across [period]. Providing it in the form sought would disproportionately divert the resources of this public authority within the meaning of Section 7(9) of the RTI Act, 2005. Accordingly, this office offers you the following alternatives: (a) Inspection under Section 2(j) at this office on [proposed date and time]. After inspection, you may identify the specific pages required, and certified copies will be supplied at the prescribed fee under Section 7(5). (b) A representative sample for [period] is enclosed. (c) If you wish to receive certified copies of the entire set, the cost intimation under Section 7(3) is approximately Rs. [amount] for [number] pages. Please confirm and remit; the time between this intimation and your payment is excluded from the 30-day clock under Section 7(3). Yours faithfully, [PIO]
Sample transfer under Section 6(3).
Sub: Your RTI application dated [DD/MM/YYYY], partial transfer under Section 6(3) Sir / Madam, Your queries at point [list] relate to records that are held by [other public authority and address]. Under Section 6(3) of the RTI Act, 2005, those queries are being transferred to that office today, and the said authority will respond directly to you. The remaining queries at point [list] are being processed by this office and will be replied within 30 days. Yours faithfully, [PIO]
Common mistakes
- Mechanical rejection of vague RTIs. Saying “vague, hence rejected” without using Section 7(9) and inspection invites penalty.
- Treating “voluminous” as exemption. Volume is not an exemption. It triggers Section 7(9) form-of-supply provisions only.
- Skipping Section 6(3) transfer. Holding on to a query for 30 days only to reject as “wrong office” is a Section 20 trigger.
- No clarification request. When the request is genuinely unclear, ask the applicant within five days; do not wait until day 28.
- Charging for inspection. First hour of inspection is free; thereafter Rs 5 per fifteen minutes (central; state varies).
- Refusing on language alone. RTI may be in English, Hindi or the official language of the area. PIO must accept and reply.
- No document trail. Every step must be in the noting; otherwise FAA and CIC reverse.
Appeal or next step
- Applicant first appeal under Section 19(1) within 30 days.
- CIC second appeal under Section 19(3) within 90 days.
- Section 20 penalty for unreasonable refusal.
- CIC suo motu directions to public authorities for systemic Section 4(1)(b) compliance, often arising out of vague-RTI complaints.
FAQs
Can a PIO reject "wide and vague" RTI?
Not on those grounds alone. The PIO must use Section 7(9), inspection and clarification first.
What is "disproportionate diversion of resources"?
A factual judgment. Compiling several thousand pages from physical files, or extracting records from non-digitised registers, may qualify. The CIC tests it case by case.
Can a PIO charge for inspection?
The first hour is free; subsequent hours are charged at the prescribed rate (Rs 5 per 15 minutes for central; state may differ).
What if the applicant does not turn up for inspection?
Record the no-show and reschedule once. After two no-shows, you may treat the inspection limb as withdrawn.
Is "no information" a valid reply?
Yes, but only after a genuine search and recorded reasons. Section 2(f) covers only information held by the authority.
What about RTI in a non-official language?
You may invite a translation, but cannot reject. Most public authorities arrange in-house translation for short queries.
How long can a clarification add to the timeline?
The CIC has accepted reasonable clarification time as excluded; but excessive delay will be reckoned against the PIO. Issue clarification within five days; do not loop multiple times.
Sources
- RTI Act 2005: rti.gov.in
- Department of Personnel and Training: dopt.gov.in
- Central Information Commission: cic.gov.in
- State ATIs and YASHADA training material
- RTI Online: rtionline.gov.in
Last reviewed: 9 May 2026.
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