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RTI timelines cheat-sheet — every deadline in one table

Eight statutory clocks govern an RTI from filing to Second Appeal: 30 days (PIO disposal), 48 hours (life-and-liberty), 5 days (§6(3) transfer), 10 days (§11 third-party notice), 30 days (First Appeal filing), 30+15=45 days (FAA disposal), 90 days (Second Appeal filing), Rs 250/day delay penalty. A PIO who misses the 30-day window must supply information free of further charge; an FAA's silence beyond 45 days is directly appealable. Every applicant and every PIO should keep this one-page table taped above their desk.

⚠️ DPDP Rules, 2025 (14 Nov 2025) amended Section 8(1)(j) of the RTI Act — public-interest override now under Section 8(2). Read the note →

· 2026/04/19 05:02 · 0 Comments

The complete timeline table

Clock Duration Section What happens on expiry
PIO disposal (standard) 30 days §7(1) Deemed refusal under §7(2); §7(6) — further information free of cost
PIO disposal (life & liberty) 48 hours §7(1) proviso Deemed refusal; §20 exposure heightened
§6(3) transfer (to correct PIO) 5 days §6(3) Transferring PIO's §20 liability crystallises
§11 third-party notice 10 days for representation §11(1) Silence — PIO may proceed with disclosure decision
§11 total disposal window 40 days (30 + 10) §7(1) + §11 Deemed refusal triggered at day 41
§7(3) additional-fee intimation Stops the 30-day clock §7(3) Clock re-starts from date of fee payment
First Appeal filing 30 days from PIO decision (or expiry) §19(1) Delay condonable on sufficient cause — §19(1) proviso
FAA disposal 30 days, extendable to 45 with written reasons §19(6) Non-decision at day 46 = deemed refusal; direct Second Appeal
Second Appeal filing 90 days from FAA decision (or expiry) §19(3) Delay condonable on sufficient cause
§20 penalty Rs 250 per day of delay, capped at Rs 25,000 §20(1) Recovered from PIO personally

Use the RTI Timeline Calculator to compute your specific deadlines with dates.

The five most common timing traps

1. Counting the 30 days wrong

The §7(1) 30-day clock runs from the date the PIO receives the RTI — not the date the applicant posted it, and not the date the applicant's fee was paid (unless the PIO invoked §7(3) fee intimation). For §6(3) transferred applications, the clock re-starts at the receiving PIO.

2. Treating the 48-hour proviso as symbolic

The §7(1) proviso for life-and-liberty RTIs is real. A PIO who receives an RTI on behalf of a hospital-admission-pending patient and sits on it for 30 days is personally liable under §20. The 48 hours are hours, not working-days.

3. Missing the §11 40-day math

When a third party is involved, the 40-day disposal window is strict:

  • Days 1-10: PIO issues §11 notice to the third party
  • Days 11-20: Third party responds (or doesn't)
  • Days 21-40: PIO decides on disclosure and communicates to the applicant

A PIO who waits till day 28 to issue a §11 notice has lost the ability to honour the 40-day window. That's §20 territory.

4. Assuming the FAA has 45 days automatically

§19(6) gives the FAA 30 days as default. The extension to 45 days is conditional — the FAA must record written reasons for the extension. An FAA who silently takes 45 days is acting outside §19(6); that's Second-Appeal-ready on procedural grounds.

5. The 90-day Second-Appeal window — not 30

§19(3) gives you 90 days for Second Appeal — three times the First Appeal window. This is often misremembered. The start date is:

  • Date of FAA decision (if delivered), OR
  • Expiry of 45 days after First Appeal filing (deemed FAA refusal)

Pick the later date, subtract 90, that's your deadline.

What to do when a timeline is missed

The PIO missed 30 days

You (applicant) act:

  1. File First Appeal immediately under §19(1) — treat silence as deemed refusal under §7(2).
  2. Claim §7(6) — request all further information free of fees.
  3. Flag §20 exposure: mention the specific number of days of delay in your First Appeal so the FAA can refer for penalty.

The PIO transferred under §6(3) but late

You (applicant) act:

  1. Demand (via First Appeal if needed) the date of transfer AND date of receipt at transferee.
  2. If transfer took >5 days, point to transferring PIO's §20 exposure.

The FAA missed 45 days

You (applicant) act:

  1. Treat it as deemed rejection.
  2. File Second Appeal directly to the CIC/SIC under §19(3) without waiting for the FAA order.
  3. In Second Appeal, raise both the substantive denial and the §19(6) procedural lapse.

You (applicant) missed the 30/90-day appeal deadline

You can still act:

  1. File with a written explanation of the “sufficient cause” — illness, address change, loss of PIO order, bereavement.
  2. The FAA (§19(1) proviso) and the Commission (§19(3)) have discretionary power to condone delay.
  3. Attach documentary proof of the cause (medical certificate, address-change receipt).

Bookmark-worthy phrases

  • “Deemed refusal under §7(2) has occurred as of [date].” — open a First Appeal with this line.
  • “The §7(3) fee intimation dated [date] stopped the clock; it re-started on [date of payment].” — use in any dispute about the 30-day count.
  • “The §11 third-party procedure was required and was not followed; the final PIO order is vitiated under the Muniyappan standard.” — for FAA/Second Appeal if §11 was skipped.
  • “The FAA extended disposal beyond 30 days without recording written reasons as required by §19(6).” — procedural challenge to late FAA order.

Discussion

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blog/rti-timelines-cheatsheet-2026.txt · Last modified: by 127.0.0.1