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INFORMATION ACCESS THROUGH RTI ACT, 2005; A TOOL TO ENHANCE CIVIC EMPOWERMENT AND ENGAGEMENT

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ANU RAPHY
Journal IJLRA
ISSN 2582-6433
Published 2024/11/14
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Issue 7

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INFORMATION ACCESS THROUGH RTI ACT, 2005; A TOOL TO ENHANCE CIVIC EMPOWERMENT AND ENGAGEMENT
 
AUTHORED BY - ANU RAPHY
 
 
(1) INTRODUCTION
Freedom of Information was identified as an integral part of Freedom of speech and expression by Resolution 59 of UN General Assembly, which was adopted in the year 1946 and under Article 19 of The Universal Declaration of Human Rights[1]. International Covenant on Civil and Political Rights (ICCPR) under Article 19 recognises freedom of speech and expression which includes within its ambit, right to seek, receive and impart information.[2] The main contributor to the Declaration of American Independence, Thomas Jefferson (1743 - 1826) believed that “an informed citizenry is the bulwark of a democracy”.[3]
 
In Indian perspective, the enactment of The Right to Information Act, 2005, which upheld the citizens right to access information held by public authorities, marks a significant milestone in India’s democratic history and it can be termed as the most significant and revolutionary piece of legislation in independent India.[4]As stated in its objectives, democracy requires an informed citizenry and access to information. Access to information is necessary for citizens to combat corruption and to hold government agencies responsible for their action. It was with this objective in mind the Act was enacted. The main goal behind its implementation was to remove the gap between the public and government, ensuring a participatory governance structure. It would be difficult to point out a single legislation other than RTI Act which has the capacity to influence the whole Indian society by providing them an instrument of power regardless of their status or categorisation. The interdependence of Right to information and freedom of speech and expression and the need for a comprehensive Right to Information Act gained momentum in the latter part of 20 th century. Civil society activism and judicial rulings play a significant role in this. At this juncture, the Right to Information Act came as a turning point, ushering a new period of openness and public participation. In addition to giving citizens the right to request information, the Act requires public authorities to proactively disclose certain information.
 
(2) HISTORICAL BACKGROUND AND EVOLUTION
OF RTI ACT IN INDIA
(2.1) BACKGROUND BEHIND THE ENACTMENT OF RTI ACT
India’s aspiration for accountability and openness dates back to its pre independence period when the fight against colonial control laid the foundations for right to information. After independence, there were sporadic legislative actions and administrative instructions to promote transparency in government but efforts to institutionalise the right to information only gradually gained pace[5]. An NGO named Mazdoor Kisan shakti Sangathan (MKSS) started a protest in Rajasthan in 1990, demanding that the government provide details of the state employment generation scheme. To spearhead a nationwide effort to enact the RTI Act, a group of activists and members of non-governmental organizations founded the National Campaign for People's Right to Information (NCPRI) in 1996. The Indian government estabilished  a committee to draft a bill pertaining to freedom of information ,with social activist Hari Dev Shourie serving as its head and thus Freedom of Infromation Bill, 2000 which later became Freedom of Infromation Act,2002 came into force.[6]Freedom of Information Act, 2002 was the first attempt in this regard.Though with a narrow scope and application, this act set the stage for  a more expansive legal framework that eventually became the Right to Information Act, 2005.
 
The culture of secrecy prevalent in the administrative domain for ages was broken by this act, which asserted peoples right to access information. India’s governance entered a new era of transparency and accountability with the passage of RTI Act. The RTI Act, which came into effect on october 12, 2005 was the result of years of activism, public hearings and court decisions that acknowledged the access to information as a fundamental freedom required for a strong democracy. The RTI Act was enacted after a protracted legislative process marked by stakeholder consultations, lengthy debates and modifications intended to reconcile the rightful concerns of public authorities with the necessity of transparency.
 
(2.2) IMPACT OF JUDICIAL DECISIONS ON EVOLUTION OF RTI ACT
The importance of imparting information to people regarding governance and actions of public authorities was reinforced by the judiciary through a series of judicial decisions.
 
State of UP v. Raj Narain & Ors[7] established that Right to know is derived from freedom of speech and expression and people of the country have the right to know about every public Act and to be ensured that everything is done in a public way by public functionaries.This idea was further reinforced in the case of Maneka Gandhi v. Union of India[8] in which court reiterated that freedom of speech and expression includes right to gather information.The significance of transparency and accountability in a democratic form of government was highlighted in SP Gupta v. President of India & Ors[9]. Further in Secretary, Ministry of Information and broadcasting,Government of India & Ors. v. Cricket Association of Bengal and others[10], Supreme Court identified as an intrinsic component of freedom of speech and expression, Right to acquire information and disseminate it.The supreme Court recognised Right to Information as the part and parcel of Right to life under Article 21 in its decision in Reliance Petrochemicals Ltd v. Proprietors of Indian Express Newspapers, Bombay Pvt Ltd and Others[11]Thus through these and many other decisions, judiciary laid down the foundation upon which present RTI Act was developed.
 
(3) ANALYSIS OF RTI ACT, 2005
(3.1) Objectives and Provisions of the Act
The Act's statement of object and reasons emphasizes its scope as a law that guarantees citizens' access to information under public authority's control and fosters accountability and transparency in government operations by establishing an institutional framework for state and central information commissions[12].The primary goal of the Act is to strike a balance between the government's competing interests in protecting information related to them and the right of individuals to be informed about government actions and decisions.All central, state, and local public entities in India are covered by the Act, including ministries, departments of government, state-owned enterprises, and independent organisations.
 
Under the provisions of the Act, the term “Information”[13] includes, any material in any form such as contracts, reports, papers, samples, models, data material held in any electronic form, opinion, advices, memos, orders logbooks and information relating to any private body that a public authority may access under any other law in force and right to Information delineats the idea of inspecting work, documents and records, taking notes, extracts or certified copies of documents or record and all other activities as mentioned under section 2 (j) of the Act.
 
With a wider scope it covers the legislative and executive branches of government as well as any organistaion that receives significant funding from government. Under sections 6 and 7, Act gives the procedure for requesting information and the manner and mandates of disposal of information, subject to the limitations and exceptions listed in sections 8 and 9 of the Act. Information that could jeopardise India’s sovereignty and integrity, the states security, strategic, scientific or economic interests or information that has been expressly forbidden from publication by a court of law or other body are all covered by these exemptions.
 
(3.2) Exceptions and Exemptions under the Act
The Act exempts from its ambit, disclosure of certain informations such as those which may effect the sovereignty and integrity of India, the security, strategic, scientific or economic interests of the state, relation with foreign state or which may lead to incitement of an offence. Section 8 (1)(b) and (c)[14]  prohibits information expressly forbidden to be published by any court of law or tribunal as well as those which could cause breach of parliamentary privileges. Informations regarding commercial confidence, trade secrets, infromation available to a person in fiduciary relationship, cabinet papers are all exempted. Apart from this there is no requirement under the Act to publish those informations, the disclosure of which may endanger life or physical safety of any person, or which may impede the process of investigation. Section 8(2) requires public authority to disclose the information if public interest outweighs the harm to protected interest Apart from this, section 9 specifies ground for rejection of access to information in case of copyright infringement.
 
(3.3) Procedure for accessing information
Every public organisation is required by section 4 of the RTI Act to maintain records, proactively publish particular type of information, and distribute information through a variety of channels such as websites, public notices and media releases. The purpose of this proactive disclosure obligation is to promote greater public understanding and involvement in governance processes, reduce the burden on PIO’s and enhance openness.
 
Apart from this realising the need of integrating technology to make information more accessible, Act streamlines and increase efficiency by allowing RTI requests and appeals to be sent electronically using email and internet platforms. In order to guarantee that information is easily accessible to citizens in a variety of locations the Act also encourages the digitisation of records and the use of electronic techniques for record keeping and dissemination. In a nutshell, The RTI Act creates a strong foundation for increasing accountability, openness and public empowerment inside India’s political system.
 
(4) CHALLENGES FACED BY RTI ACT
However years after its enactment, the effectiveness of the Act is still a question. As per the statistical data published by Satark Nagarik Sangathan[15] an NGO in India, with the aim to promote transparency and accountability among governing bodies in its 2022-23 report demonstrates the current scenario revolving Information Commissions and their working.As per the data published there are 3,88,886 pending appeals before central and various state commissions and as on October 2023 in four states, Information Commissions were not at all appointed.
 
(4.1) Huge number of pending cases
One of the major issues confronting India’s accountability system is the substantial backlog in processing of grievances and appeals. Due to this, applicants have to wait for months and even years for their cases are to be heard by Information commissions and this negates the timely access to information guaranteed bt RTI Act. As per the data published by Satark Nagrik Sangathan (SNS) or Society for Citizens Vigilance Initiatives (SCVI), set up in 2003, is a citizens’ group with a mandate to promote transparency and accountability in government functioning, 3,88,886 cases are pending for disposal as on June 30,2023.[16]The entire idea of access to information and transparency wil become meaningful only if it is provided within a reasonable time. Inordinate delay in disposing of requests renders the very objective of the Act a failure.
 
(4.2) Bureaucratic opposition
The implementation of Right to information Act in India has significant challenges due to institutional impediments and bureaucratic resistance within government agencies and public entities. Even though its required by law to provide citizens with information, many public officials are reluctant to embrace its transparency because they see RTI Act as a threat to their authority and independence.[17] The opposition often leads to public information officers addressing RTI requests using evasive techniques, refusals and delays.
 
Bureaucratic obstacles involving overbearing redtapism, convoluted processes and a lack of accountability measures make it harder for the RTI system to function effectively.[18] Public Information officer’s may use delay strategies to discourage applicants and deter them from seeking information such as asking unwanted explanations or forwarding requests to other departmnets. Implementation of Act is further complicated due to absence of guidelines for proactive disclosure and a culture of secrecy, which encourage opacity and non- cooperation in bureaucratic circles.
 
(4.3) Insufficient proactive disclosures
The lack of proactive disclosure by governmental institutions is another significant barrier to the RTI Act’s enforcement in India. Even though section 4 of the Act requires public entities to proactively publish certain kinds of information through required publication schemes, compliance with these requirements is nevertheless erratic and uneven. In Kishan Chand v. Union of India[19] directions have been given by Supreme Court of India to Information Commission for effectively monitoring implementation of section 4 of the Act. Many governmental organisations view proactive disclosure as only a procedural need rather than an significant obligation which leads to the partial or selective release of pertinent public information.
 
(5) ROLE OF RTI IN ENHANCING GOOD GOVERNANCE
The term “governance” means the process of decision making and its implementation with welfare of society as the main goal. Any government can govern a society but for a governance to become good governance it need to fulfill certain criterias such as Transparency, Accountability, Participatory, Responsive, inclusive of all sections of people and follows rule of law. It ensures that corruption is avoided and the voice of the most disadvantaged sections of society are also taken care of.
 
(5.1) Transparency in governmental activities
In State of Uttar Pradesh v. Raj Narain[20], the Honourable Supreme Court held that, the citizens of the country have a right to be informed about every public action taken by their public servants. They have a right to be informed about every detail of public transaction, regardless of its significance. The right to know which is derived from the idea of free speech though not absolute is a reason to exercise caution when concealment is demanded for transactions by public authorities. The idea that disclosure of information should be a rule and secrecy an exception was highlighted in SP Gupta v. President of India and Ors[21].By nurturing the culture of openness and answerability in formulating and, implementing policies and decisions, the Act enhance transparency in decision making. By ensuring that governmental actions comply with the values of impartiality, fairness and public welfare transparency in decision making promotes public trust and confidence in the democratic system.
 
The Act gives public access to information about the factors that go into making government choices, how policies are formulated and what influences are used to shape executive and legislative actions. Because of its transparency, public officials may be held accountable for their actions and citizens are able to closely monitor the decision making process, which serves as a check against arbitrary authority exercises and excessive pressure.[22]Apart from that having access to information enables people to participate actively in political discourse, offer suggestions for policy changes and push for laws that better represent their concerns and interests.
 
(5.2) Accountability
As it empowers citizens to hold government agencies and officials accountable for their actions, the RTI Act is essential in promoting accountability in the delivery of public services. By using RTI requests, citizens can monitor the effectiveness, efficiency, and integrity of public government by obtaining information on the distribution of resources, the execution of programs and the provision of essential services. This accountability process exposes inadequacies, anomalies and instances of failure to execute legal tasks so serving as a deterrent against mismanagement, corruption and misuse of authority.
 
Other than that the possibility of public examination endangered by the RTI framework encourages public bodies to improve processes for providing services, increase transparency in their opertaions, and put policies in place to prevent and handle compalints. The Act fostrs an environment of openenss and accounatbility by providing the public with access to ifromation on government programs and spending. This means that public servants are accountable to both the people they represent and their superiors. In the provision of public services, this accountability cycle upholds the principle of good governance, integrity and moral behaviour.
 
(5.3) Participatory governance
For people to participate in decision making process they should be aware of all governmental actions and policies. Every public authority is expected to keep all of its records appropriately in order to ensure the greatest possible exposure of information about government laws, regulations, and reports, including decision-making processes. Therefore, under section 4 of the Act, it is incumbent of the public authorities to make proactive disclosures by disseminating information over the internet and publishing pertinent papers.
 
(5.4) Avoidance of corruption
Most of the corrupted activities happen in the absence of proper checks and controls and in the confidence that no one is watching. RTI Act was enacted with avoidance of corruption as one of its objectives. When government is under an obligation to disclose all their activities to public corruption can rarely happen.
 
 
(5.3) Inclusiveness
Encouraging civic engagement and participation is essential for good governance. By providing citizens tools and knowledge to required to participate effectively in decision making, the Act strengthens democratic institutions, encourage community engagement, and increases the legitimacy of governmental actions[23].RTI requests are a useful tool for citizens to gather information, spread knowledge of issues of public concern and mobilise support for initiatives and policy changes that align with their value and aspirations.
 
In addition the RTI Act creates channels for positive communication and feedback, which encourages dialogue, coordination and cooperation between governmental and non governmental organisations. By advocating for changes to governmental policies, programs and processes, citizens can use the information obtained through RTI requests to support more inclusive and receptive governance. By fostering a sense of accountability and acommunity among residents, this participatory approach to government strengthens social cohesion and propels the realisation of democratic values like empowerment, fairness and justice.
 
(5.4) Role of media and civil society
Media is considered as a key player in the growth of information society and act as a major promoter of freedom of expression and plurality of information[24]They are ubiquitous and have a big impact on how societies are shaped; they create the public forum for discussion and information that promotes social and cultural dialogue, engagement, and accountability.[25]
 
There is an increasing recognition that, in order to achieve desired outcomes, people must be involved in the creation and execution of public policies and programs. In a countrys growth process, through advocacy, research and supervision efforts , civil society organisations and the media play a crucial role. To improve the RTI framework, civil society organisations, media and governmental agencies must work together more closely to identify challenges, supervise implementation and push for improvements. A proactive civil society is essential to ensure successful government. CSO can conduct public forums on RTI related problems, provide legal aid to applicants, and push for legislative changes to strengthen the RTI regime by utilising their networks and areas of expertise.
In the same way media through their investigative reporting and coverage are crucial in exposing wrongdoing, corruption and abuse of power. The RTI Act should be promoted to journalists and media organisations as a means of doing investigative journalism, gaining access to official records and information and holding public servants responsible for their actions. Increasing public participation in governance processes, facilitating information transmission and enhancing transparency are all possible through fortifying partnerships between media, civil society organisations and the government.
 
Achieving the concept of good governance in its entirety is a challenge and so far no country have successfully achieved it but we can tread the path to good governance with the aid of RTI Act. Good governance is a process and effective implementation of RTI provisions which aims at attaining transparency and accountability helps in smooth flow of that process.
 
To summarise, the Right to Information has noteworthy consequences for advancing good governance in India by augmenting transparency in decision making procedures, motivating accountability in public service delivery and cultivating citizen involvement and involvement in governance. However in order to fully realise the benefits of the Act, coordinated efforts must be made to address implementation obstacles, strengthen institutional capacities and establish a culture of openness and responsiveness in both governmental and nongovernmental organisations.
 
6. SUGGGESTIONS AND RECOMMENDATIONS
(6.1) Policy measures
An indepth analysis of Right to Information Act reveals policy implications as india moves forward in its attempts to advance accountability and openness in governance. These ramifications are essential for directing upcoming legislative initiatives meant to promote public empowerment and strengthen democratic governance.
 
The requirement for continuous legislative modifications to address changing issues and shortcomings in the RTI system is one significant policy effect. This included making the Act’s exceptions more understandable and logical expanding its application to include private organisations carrying out public functions and stiffening the penalty for breaking the law. In addition to that legislators ought to think about enacting policies that simplify RTI process, remove administrative roadblocks and promote proactive information sharing by government agencies.
 
(6.2) Improving institutional infrastructure
Other than enacting new laws there are a number of strategies that can be used to improve accountability and openness in government, expanding on the foundation laid by RTI Act.[26] Firstly in order to effectively implement the Act, institutional capacities must be strengthened. This includes investing in information technology infrastructure to digitize records and enable online access to information as well as training Public Information Officers and Information commissions. Both the centrall and state governments are also responsible to make sure that necessary number of information commissioners are appointed on time and set a minimum limit upon the number of cases to be disposed by each Information Commissioner. This will improve their efficiency as since they have to meet a target they will look through the complaints received. Disposed cases if mentioned in a database will avoid the workload of Commisssion by avoiding the instances of dealing with same kind of complaints by more than one person during same or different period of time.
 
(6.3) Imposing duties and penalties on head of the departments
In the case of proactive disclosure under section 4, which is the duty of public authority, they shall be punished for its non performance.[27] This measure may reduce the number of pending cases as public need not submit an RTI application for those informations which are already available in website. Very often department websites remain not updated. This situation can be resolved by making head of the departments liable. The capability of Information commission to utilise such implied powers were mentioned in Sakiri Vasu v. State of Uttarpradesh and Ors.[28]Apart from this, penalty should also be imposed for failure in maintaining department records.
 
(6.4) Creating awareness among people
Efforts must be taken to cultivate an environment of transparency and accountability in governmental organisations by means of awareness campaigns, workshops and capacity building programs. Public servants must be inspired to embrace openness as a core value and understand the importance of proactive disclosure in building public confidence. In a same sense, people ought to have the authority to claim their right to knowledge, engage in political processes and hold public servants responsible for their actions.
 
(6.5) Enhance role of media and civil society
Through advocacy, research and monitoring efforts the media and civil society organisations play a critical role in promoting accountability and transparency. As partners in governance, policy makers ought to interact with civil society organisations and the media using their expertise, connections and assets to supervise execution, pinpoint shortcomings and promote modifications.[29] Strengthening partnerships between governmental organisations, civil society organistaions and the media can enhance transparency, promote the sharing of information and encourage greater public participation in governance procedures. In conclusion the comprehensive methods incorporating institutional fortification, stakeholder engagement and legislative amendments are necessary for future efforts to advance openness and accountability in India’s governnanc elandscape. Policy makers can move closer to the objectives of good governance, democratic empowerment and holistic development in India by including transparency and accountability concerns into policy making and execution.
 
(6.6) Need for expanding the scope of public authority
The term public Authority has been defined under the Act "Public authority" refers to any body, institution, or authority of self-government that is established or constituted by or under constitution or any other legislations made by parliament or state legislatures or appropriate government notifications. It includes body owned, controlled, and non-governmental organization, which are substantially financed either directly or indirectly, by funds provided by the appropriate Government. An examination of this definition gives an idea that it includes, all bodies created by or under Constitution of India as well as by other statutes. Thus all constitutional, statutory and local self government bodies are public authorties and it includes state legislature, parliament and judiciary also. The second part of the definition highlights that all bodies, owned, controlled and substantially financed directly or indirectly by funds provided by central or state governments are also Public Authorities. However the term substantially financed is no where defined in the Act.[30]Under the term state all those who are a part of it also constitutes state and applying the same logic to the terms of legislature, parliament and judiciary, each and every person constituting those organs are also amenable to the provisions of RTI Act.[31]
 
So far private entities and public charitable trusts are exempted from the ambit of RTI Act. In the current scenario where private entities undertakes public functions, there is a need for extending the ambit of RTI Act keeping in mind the very objective of the Act. Be it a private or public Authority no individual or entity in the country have the authority to indulge in shady businesses.
 
There is also an increasing trend by state and central government establishing relief funds under various heads and denying the transparency in the name of public charitable trust. These trusts established either under the name of Chief Minister of the State or Prime minister of the country receives huge donations from the public in good faith. Doesn’t a person who contributes a portion of their wealth or income have the right to know how and where it was utilised? A fund established in the name of authorities presupposes genuineness to some extent and this trust and faith of people in the government initiatives is being utilised here. If fund is used completely for genuine reasons, what is prohibiting them from disclosing the fund allocation?
 
A fund constituted by a constitutional machinery, where board of trustees are appointed by them, where there are some budgetary allocations for their advertisements, and which recieves substantial amount of funding from other government departments as in the case of PMCARES, there should be disclosure as to the ways in which fund was used.
 
In split verdict by division bench of Delhi High Court such funds were considered as public Authorities. In accordance with the preamble of RTI Act, transparency and account a beerlessility are the essentials for the functioning of public authority. As stated by Reserve bank of India v. General Finance and Investment Co. Ltd[32], Interpretation of a statutory provision must depend upon the context and text. The context behind enactment of RTI Act was to bring transparency in all walks of public Authorities. If there are possibilities for hidden motives under some other ground the whole RTI Act will become a failure.
 
CONCLUSION
Everyone has the right to access the information that public agencies hold since they are guardians of the public good The Right to Information Act Is an important tool for bringing about social changes and increasing transparency in administrative system. It represents hope for India's efforts to achieve accountability, openness and sound government. For an Act to achieve its full and effective implementation, awareness of people about the statute is necessary, the failure of which will render its objectives to remain in paper.
 
There are number of obstacles in the way of promoting accountability and openness in governance. The RTI Act’s transformative influence is limited by bureaucratic opposition, insufficient proactive disclosure and shortcomings in enforcement procedures that continuously impede its effective execution. Coordinated efforts from all parties involved - policy makers, public servants, civil society organisations and the media are necessary to overcome these obstacles Maintaing the RTI framework and accomplishing its goals will require continued legislative changes, efforts to create capacity and involvement with stakeholders. The main goals of policy interventions should be to make exceptions more understandable and logical to make non compliance sanctions stronger and to incorporate transparency concerns into larger governance reforms. In addition, the government, which has demonstrated such wisdom and bravery in passing the act, must make sure that the agencies in charge of carrying it out don't lack resources so they can perform to the best of their abilities. Initiatives to improve institutionalised capacities, increase public awareness and promote cooperation between the media, civil society and government agencies are also essential. Free and open exchange of information is the cornerstone of successful government. Through a collaborated effort we can make changes in the political landscape of our country by creating transparency, responsiveness and accountability.


[1] UNITED NATIONS AND THE RULE OF LAW, https://www.un.org (last visited Sep.4,2024).
[2] RTI KNOWLEDGE PORTAL, https://rti.img.kerala.gov.in (last visited Sep 4,2024)
[3] Gaddela Srikanth, Unlocking the access: Examining the right to Information legislations of India and Bangaldesh, Third Concept,14,15-17 (2024)
[4] OP Kejriwal, Right to Information Act; Loopholes and Road ahead, 41, Money, banking and Finance, EPW, 940, 940-941, (2006)
[5] A Archana, Analysing openness: An in depth evaluation of the right to Information Act and its impacts on effective governance in India, 41 Juni Khyat, 29, 30 -37, (2024)
[6] Nilotpal Bhattacharjee,Newspaper Coverage and awareness of Right to information Act : A case study in Assam, 22 SIJSS,198, 199-211, (2024)
[7] State of UP v. Raj Narain & Ors,1975 AIR 865
[8] Maneka Gandhi v. Union of India, AIR 1978 SC 597
[9] SP Gupta v. President of India & Ors, AIR 1982 SC 149
[10] Secretary, Ministry of Information and broadcasting,Government of India and Others v. Cricket Association of Bengal and Others,1995 AIR 1236
[11] Reliance Petrochemicals Ltd v. Proprietors of Indian Express Newspapers, Bombay Pvt Ltd and Others, 1989 AIR 190
[12] Right to Information Act, 2005, S.3, No.22, Acts of Parliament, 2005 (India)
[13] Supra Note 5
[14] Right to information Act, supra note 12
[15] SATARK NAGARIK SANGATHAN, https://www.snsindia.org, last visited Sept 6, 2024
[16] Michael Riegner, Access to Information as a Human Right and Constitutional Guarantee. A Comparative Perspective,50, LPAALA,332, 332-366 (2017)
[17] Pankaj KP Shreyaskar, Investigating compliance of RTI Act, 48 EPW,19,19-22, (2013)
[18] Anshu Jain, Good Governance and Right to Information: A perspective, 54 JILI 506, 506-519, (2012)
[19] Kishan Chand v. Union of India, AIR1976 DEL 265
[20] State of Uttar Pradesh V. Raj Narain,1975 AIR 865
[21]  SP Gupta v. President of India and Ors, AIR 1982 SC 149
[22] Sahina Mumtaz Laskar, Importance of Right to Information for Good Governance in India, BLR (2016)
[23] WHAT IS GOOD GOVERNANCE?, https://unescap.org. Last visited Sept 08,2024
[24] WORLD SUMMIT ON INFORMATION SOCIETY,https://www.itu.int/, last visited Sept 08,.2024
[25] Supra Note 16
[26] Mahua Sengupta, Awareness of Right to Education Act, 2009 among the Tribal parents, A study on dakshin Dinajpur District, 9 RRIJM, (2024)
[27] REPORT CARD ON INFORMATION COMMISSIONS OF INDIA, https://snsindia.org Last visited Sep 08,2024
[28]Sakiri Vasu v. State of Uttarpradesh and Ors.( 2008)2 SCC 409
[29] Nilotpal Bhattacharjee, Newspaper coverage and awareness of Right to Information Act: A case study in Assam, 22 SJSS 3, 3-14, (2024)
[30] PM CARES FUND: AN AMBUSH ON THE RTI ACT, https://lawctopus.com Last visited on Sep 05, 2024
[31] N Sai Vinod,Attempts to Erode RTI Mechanism, 49 EPW 30, 30-32, (2014)
[32]Reserve bank of India v. General Finance and Investment Co. Ltd ,1987 AIR 1023

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