An evaluatory note on the subject-matter pattern of Right to Information applications in India. Drawn from the annual reports of the Department of Personnel and Training, the published reports of the Satark Nagrik Sangathan, and the case-law line at the Central Information Commission and the Supreme Court. The note is for applicants, Public Information Officers, First Appellate Authorities, and researchers who want to see where the Act works, where it stops, and why.

The empirical observations in this note are drawn from three classes of source.

• Department of Personnel and Training (DoPT), Annual Reports on the implementation of the Right to Information Act. These carry the aggregate number of applications received, transfers under Section 6(3), denials, and the clause of Section 8 most often cited. The reports from 2005-06 onwards are published at the DoPT website.
• Satark Nagrik Sangathan, Report on the Performance of Information Commissions in India. The annual series tracks the composition, pendency, and disposal pattern of the Central Information Commission and the State Information Commissions. The 2024-25 report noted aggregate pendency of over four lakh appeals and complaints across the State Commissions.
• Central Information Commission annual returns, and the published orders. Individual orders record the ground of refusal, the decision of the Commission, and the direction to the Public Information Officer. The pattern across hundreds of orders gives the shape of the appeal docket.

The numbers used here are indicative, not definitive. Every applicant and every public authority is different. The observations below are the prevailing pattern, not a prediction about any particular matter.

Across the central Government, the State Governments, and the Union Territories, five subject areas account for the largest share of the annual RTI filing.

1. Service matters of the applicant's own employment. Applications by serving and retired Government employees for their own Service Book, Annual Performance Appraisal Reports, leave record, increment and promotion orders, transfer orders, and disciplinary records. The single largest category across both central and State Governments, on DoPT's aggregate reporting.
2. Land records, revenue, and municipal records. Applications for patta, khata, mutation entries, survey records, building-plan sanction, occupancy certificates, and local body works. Very heavy in States with computerised land-record portals running parallel to RTI.
3. Pension and retirement benefits. Applications on pension computation, leave encashment, gratuity status, PF withdrawal timelines, and family pension sanction.
4. Police, First Information Reports, and administration. Applications for a certified copy of the FIR, status of investigation, copy of the case diary where permissible, investigating officer's details, and complaint status.
5. Education and examinations. Applications for marksheet verification, the evaluated answer sheet (after Central Board of Secondary Education v. Aditya Bandopadhyay, (2011) 8 SCC 497), scholarship status, admission-process records, and recruitment-examination records.

Other recurring categories include income-tax refund status, passport and visa processing, ration card and public-distribution records, IRCTC refund on tickets, and records of MP and MLA Local Area Development Scheme funds.

Evaluatory note. The filing pattern is driven by the applicant's own stake. The largest share is “my own record” requests. The second largest share is “records relating to a decision the applicant is about to challenge” — a sanction, a refusal, a transfer, a promotion. Every Public Information Officer who drafts a reply is drafting into this pattern.

A “satisfactory reply” here means one that the applicant accepts without filing a first appeal. The public-domain data shows a strong concentration of satisfactory replies in three categories.

1. The applicant's own personal record. A Government employee's request for a certified copy of his or her own Service Book is ordinarily disclosed without objection. Section 8(1)(j) does not apply to the applicant's own information. The Supreme Court in Central Board of Secondary Education v. Aditya Bandopadhyay, (2011) 8 SCC 497, confirmed that the applicant's own evaluated answer sheet is disclosable. These “own record” requests generate little appellate traffic.
2. Structured records already published under Section 4. Orders, notifications, circulars, tender documents, allotment lists, budget documents, and similar structured records are ordinarily disclosed on request, often by pointing the applicant to the published source. These requests rarely turn into an appeal.
3. Requests tied to a statutory duty and a prescribed timeline. A request for the date of receipt of an application, the time remaining on a statutory period, or the name of a concerned officer is ordinarily disposed of within the thirty-day Section 7(1) window.

Evaluatory note. The pattern of satisfaction tracks the pattern of clarity. Where the record is identified, the statute is clear on disclosure, and the Public Information Officer has no discretion to deny, the reply is timely and the applicant has no ground of appeal. These are the matters that form the majority of the Act's day-to-day work.

The Commission's docket is driven by a narrower set of subject-matters. The recurring grounds of appeal fall into the following categories.

This has been the single most-cited exemption in RTI refusals. Typical requests that engage clause (j):

• Service record of another Government employee.
• Annual Property Returns of a named officer.
• Disciplinary proceedings against a named officer.
• Recruitment records of other candidates.
• Information relating to a named company director or trustee.

The leading authority has been Girish Ramchandra Deshpande v. Central Information Commissioner, (2013) 1 SCC 212. The Supreme Court held that the information pertaining to the service and conduct of a public servant is personal information under Section 8(1)(j). The 14 November 2025 amendment to clause (j), by Section 44(3) of the Digital Personal Data Protection Act, 2023, has removed the public-interest override from within the clause. The public interest reasoning now operates through Section 8(2). A first generation of post-amendment orders will set the new appellate pattern. See Section 8(1)(j) after the DPDP Rules, 2025.

Applications for instructions to examiners, model answers, moderation standards, inspection reports of regulators, and internal evaluation records are often refused on Section 8(1)(e). The Supreme Court in Institute of Chartered Accountants of India v. Shaunak H. Satya, (2011) 8 SCC 781, held that the examiner-candidate relationship is not fiduciary in the sense of Section 8(1)(e), and in Reserve Bank of India v. Jayantilal Mistry, (2016) 3 SCC 525, held that a regulator does not stand in a fiduciary relationship with the entities it regulates. The Commission's post-Jayantilal Mistry line has narrowed the Section 8(1)(e) refusal.

Applications for records of pending investigations, case diary entries, inspection reports of investigative agencies, and departmental inquiry records are often refused on Section 8(1)(h). The Delhi High Court in Bhagat Singh v. Chief Information Commissioner, 3 December 2007, held that the public authority must show that the disclosure would impede the investigation, not merely that an investigation is in progress. The recurring question on appeal is whether the public authority has met that burden.

Applications for file notings, Office Note Sheets, inter-departmental consultation, and the reasoning behind a particular decision are often refused on a mix of Section 8(1)(e), 8(1)(g), and the generic plea of internal process. The Central Information Commission's line has been that the notings form part of the record of the public authority and are disclosable, save where a specific clause of Section 8(1) applies. The pattern on appeal is for the Commission to direct the disclosure of the notings with redactions under Section 10 where necessary.

Applications where the information sought is about a third party engage Section 11. The common grounds of appeal are delay in issuing the Section 11(1) notice within five days, failure to consider the third-party representation, or refusal to disclose after the third-party objection. See Third-party — practitioner note for the procedural timeline.

A set of refusals turn on the claim that the requested record is not traceable, has been destroyed, or was never maintained. The Commission's line has been that the Public Information Officer must record a search report, produce the register of destruction, and, where relevant, show the rule that governed the retention period. A mere statement that the record is not available does not discharge the statutory duty. See Missing files under the RTI Act.

Applications relating to political functionaries, party funds, the Prime Minister's Office, Cabinet Committee records, and individual Ministers often attract a refusal on a combination of Section 8(1)(a), (e), (h), and (j). The Central Information Commission has held that the office of a Minister is a public authority under Section 2(h) (see Ministers under the RTI Act). Implementation has been uneven. The Electoral Bonds judgment Association for Democratic Reforms v. Union of India, (2024) 5 SCC 1, re-anchored the Article 19(1)(a) constitutional right to know about political funding.

Applications for the Office of the Chief Justice of India, judges' declarations of assets, collegium deliberations, and correspondence between the Supreme Court and the Government are a specialised appellate stream. The Constitution Bench decision in Central Public Information Officer, Supreme Court of India v. Subhash Chandra Agarwal, (2020) 5 SCC 481, held that the Office of the CJI is a public authority and that the Section 8(1)(e) and Section 8(1)(j) tests are to be applied case by case, with Section 8(2) balancing.

Applications for Reserve Bank of India inspection reports, Securities and Exchange Board of India orders-in-original, and similar supervisory records have been denied on Section 8(1)(e) fiduciary and Section 8(1)(d) commercial confidence. The Supreme Court in RBI v. Jayantilal Mistry, (2016) 3 SCC 525, cleared the fiduciary point in favour of disclosure.

Across successive DoPT annual reports, the grounds most cited in refusals are, in order of frequency:

1. Section 8(1)(j) — personal information.
2. Section 8(1)(e) — fiduciary relationship.
3. Section 8(1)(h) — investigation.
4. Non-availability of the record.
5. Section 11(1) — third-party objection.
6. Section 24 — exempted organisations.
7. Section 8(1)(d) — commercial confidence.
8. Section 8(1)(a) — security, sovereignty, strategic.
9. Section 9 — infringement of copyright.
10. Section 8(1)(g) — endangerment.

Clause (j) has been the largest single ground across the years covered. The 14 November 2025 amendment will change the shape of the numbers; the next two DoPT annual reports will be the baseline for how the amendment plays out in practice.

The mismatch between subjects filed and subjects satisfied has three structural causes.

1. The Act gives the Public Information Officer discretion that the exemption clauses do not tightly cabin. Clause (j) on “personal information” is a term of art; clause (e) on fiduciary is a term of law. Both require legal reasoning that a departmental Public Information Officer may not be trained to do. The denial is often over-broad.
2. The Public Information Officer carries a penalty risk under Section 20 for wrongful disclosure but no corresponding risk for wrongful refusal. The incentive structure favours caution. The Commission's role is to correct the caution, but the correction runs through an appeal.
3. The Commissions are under-resourced. The Satark Nagrik Sangathan reports document pendency of over four lakh appeals and complaints in the State Commissions in 2024-25, and periods of below-strength composition at the Central Information Commission. A delayed second appeal does not correct a wrongful first-stage refusal in time.

Evaluatory note. The mismatch is not an indictment of the Act. It is a well-documented feature of any regime that combines broad grounds of refusal with limited enforcement capacity. The Act has delivered on its primary promise of placing government records within the reach of the citizen. The appellate workload is the price of the broad right.

For the applicant, five practical takeaways follow.

1. Frame the request around the applicant's own record where possible. Section 8(1)(j) and Section 8(1)(e) do not apply to one's own information.
2. Cite the file number or identifier. A tight identifier removes the “no such record” refusal.
3. Ask for documents, not opinions. The Act gives access to existing records, not to reasons a public authority has not recorded.
4. For a third-party matter, expect a Section 11 notice and a forty-day timeline. Plan accordingly.
5. After 14 November 2025, expect more Section 8(1)(j) denials on the substituted clause. Frame any public interest ground around Section 8(2) and the Puttaswamy proportionality limbs.

For the Public Information Officer, three takeaways.

1. The file noting is the primary record for the appeal. A Public Information Officer's reply is only as strong as the reasoning on file.
2. A Section 10 severance is ordinarily better than a Section 8 refusal. The Commission line favours disclosure of the non-exempt part.
3. Section 11 and the forty-day timeline are procedural. Miss them and the appeal lies on procedural grounds alone.

For the First Appellate Authority and the Commission, the challenge is the backlog. Anjali Bhardwaj v. Union of India, (2019) 10 SCC 1, directed timely appointments; the 2024-25 Commission composition numbers suggest the direction has been partially met. The next decade of practice will test whether the Commissions can dispose of the substituted-clause (j) appeals at the scale the amendment is likely to generate.

• The Right to Information Act, 2005 — a decade of change, 2015 to 2025. The macro picture of legal change.
• Section 8(1)(j) after the DPDP Rules, 2025: the PIO's reply, the file noting, and the practice. The drafting note.
• DPDP Rules, 2025: The amendment to Section 8(1)(j) of the RTI Act. The amendment itself.
• Case law library. The curated landmark decisions.
• Guide for applicants. The step-by-step drafting note.
• Grounds for rejection. Concept-wise note on the ten exemptions.
• Missing files under the RTI Act. On “no such record” refusals.

1. Department of Personnel and Training, Annual Reports on the Implementation of the Right to Information Act, 2005, successive years. Available at the DoPT website.
2. Satark Nagrik Sangathan, Report on the Performance of Information Commissions in India, annual series. Most recent: 2024-25, released 12 October 2025.
3. Second Administrative Reforms Commission, Right to Information — Master Key to Good Governance, First Report, June 2006.
4. Central Information Commission, Annual Returns, successive years. Available at cic.gov.in.
5. State of U.P. v. Raj Narain, (1975) 4 SCC 428.
6. Central Board of Secondary Education v. Aditya Bandopadhyay, (2011) 8 SCC 497.
7. Institute of Chartered Accountants of India v. Shaunak H. Satya, (2011) 8 SCC 781.
8. Chief Information Commissioner v. State of Manipur, (2011) 15 SCC 1.
9. Bihar Public Service Commission v. Saiyed Hussain Abbas Rizwi, (2012) 13 SCC 61.
10. Girish Ramchandra Deshpande v. Central Information Commissioner, (2013) 1 SCC 212.
11. Reserve Bank of India v. Jayantilal Mistry, (2016) 3 SCC 525.
12. K. S. Puttaswamy v. Union of India, (2017) 10 SCC 1.
13. Anjali Bhardwaj v. Union of India, (2019) 10 SCC 1.
14. Central Public Information Officer, Supreme Court of India v. Subhash Chandra Agarwal, (2020) 5 SCC 481.
15. Association for Democratic Reforms v. Union of India, (2024) 5 SCC 1.
16. Bhagat Singh v. Chief Information Commissioner, Delhi High Court, 3 December 2007.
17. Digital Personal Data Protection Act, 2023 (No. 22 of 2023), Section 44(3).
18. Digital Personal Data Protection Rules, 2025, notified on 14 November 2025.

19 April 2026