Drafting Speaking PIO Replies — A Practical Guide

Section 7(8)(i) — when the PIO rejects a request, the communication must include the reasons for rejection, the provisions of the Act on which rejection is based, and the name and designation of the appellate authority.

Section 7(1) — 30-day deadline (48 hours for life/liberty).

Section 19(5) — burden of proving justified denial rests with the PIO.

Section 4 — proactive-disclosure obligations that may pre-empt the RTI.

• Reasoned, not mechanical. Each question gets its own reasoning; don't bundle.
• Sub-clause specific. “Section 8” alone is not a reason; “Section 8(1)(j)” + explanation is.
• Section 8(2) balancing. Record the public-interest balancing on the file, even if the conclusion is refusal.
• Section 10 severability. Always consider partial disclosure before refusing.
• Address each question. If 7 questions were asked, 7 answers are required.
• Appealable outcome. The FAA's name + address must appear in the reply.

1. Reference block — RTI number, date of receipt, applicant's name, public authority, list of questions.
2. Decision on each question — answered / partially answered / declined, with the specific sub-clause where declined.
3. Reasoning — for each decline: why the sub-clause applies; the Section 8(2) public-interest balancing performed; the Section 10 severability consideration.
4. Enclosures — certified copies or schedules.
5. Fee note — Rs. 2/page for copies; calculation stated.
6. Appeal rights — FAA's name, designation, office, 30-day window under Section 19(1).
7. PIO signature block — name, designation, office stamp, date.

Ref: RTI/[Authority]/[Year]/[Sr. No.]
Date: DD-MM-YYYY

To,
[Applicant Name, Address]

Subject: Reply to your RTI application dated DD-MM-YYYY under Section 7 of the Right to Information Act, 2005.

Sir/Madam,

Your RTI application received on DD-MM-YYYY seeking the following information has been examined.

Questions raised:
1. [Question 1]
2. [Question 2]
3. [Question 3]
...

Reply, question-wise:

1. [Question 1]: Answer — [substantive answer] / Certified copy at Annexure A.

2. [Question 2]: Declined under Section 8(1)([sub-clause]) for the following reasons: [reasoning]. Section 8(2) balancing considered; no larger public interest pleaded; severability under Section 10 not reasonable on the record.

3. [Question 3]: Answer — [substantive answer].
...

Fee calculation: Rs. 2 × __ pages = Rs. _____ payable vide enclosed challan / UPI QR.

The applicant is informed of the right to file First Appeal under Section 19(1) within 30 days before:
The First Appellate Authority,
[Name, Designation, Office Address].

Yours faithfully,
[Signature]
[Name, Designation], Public Information Officer
[Office, Date]

• Bundled refusals. “All questions rejected under Section 8” — struck down at appeal.
• Missing sub-clause. Bare “Section 8” without (a)/(d)/(e)/(h)/(i)/(j) identification.
• No Section 8(2) balancing. The proviso is not optional.
• No Section 10 severability analysis. Especially for mixed records.
• No FAA contact — procedural non-compliance.
• Late reply without deemed-refusal acknowledgement — compounds the breach.
• Cryptic one-liner. “Matter in process” is not a reply.
• Refusing to accept applications. Section 6(1) requires acceptance; Speed Post is valid filing.

• Pre-decisional note on file. Write the Section 8(2) balancing note BEFORE drafting the reply; attach as the internal file-note.
• Template library. Keep sub-clause-specific templates (we have 9 at PIO RTI reply guide).
• Cite case law briefly. One line per citation beats over-citation.
• Quote Section 10 by name. “Severability under Section 10 considered and not possible because X” is stronger than silence.
• Call the FAA if in doubt. Pre-decisional consultation is permissible and often prevents a remand.

• Bhagat Singh v. CIC (Delhi HC 2008) — cryptic refusals are not speaking orders.
• R.K. Jain v. UoI, (2013) 14 SCC 1 — reasons for denial required on the record.
• CBSE v. Aditya Bandopadhyay, (2011) 8 SCC 497 — denial must be anchored to specific statutory exemption.

Q1. Can the PIO simply say “information cannot be disclosed”?
No. Section 7(8)(i) requires reasons, the specific provision, and the FAA contact.

Q2. What if all questions fall in a single exemption?
Address each question separately; cite the sub-clause once and apply it to each question.

Q3. Is email reply valid?
Yes, under Section 7(1) — but keep physical / digital signature on record.

Q4. Can the PIO charge advance fee before replying?
Yes, under Section 7(3) — intimate the fee calculation + mode of payment first; the 30-day clock pauses till fee is received.

A speaking reply is a short legal document — reasoned, specific, severable, timely, appealable. The PIO who invests 20 minutes in the reply saves 20 hours in First and Second Appeal defence.

• PIO RTI reply guide — 7 steps + 9 templates
• Section 8(1)(j) framework
• Section 10 severability
• FAA speaking-order guide
• PIO & FAA knowledge base

• RTI Act, 2005, Sections 7, 8, 10, 19
• Bhagat Singh v. CIC (Delhi HC 2008)
• R.K. Jain v. UoI, (2013) 14 SCC 1

Last reviewed: 21 April 2026.