Table of Contents
Chief Information Commissioner v. State of Manipur
Supreme Court of India · 2011-12-12 · (2011) 15 SCC 1 · ★ Landmark
§18 complaint ≠ §19 appeal. Commission cannot direct disclosure of information under §18; only §19 permits that.
Case details
| Court | Supreme Court of India |
|---|---|
| Decided | 2011-12-12 |
| Citation | (2011) 15 SCC 1 |
| Bench | Aftab Alam, Ranjana Prakash Desai |
| Petitioner | Chief Information Commissioner |
| Respondent | State of Manipur & Anr. |
| RTI Act sections | §18, §19 |
| Outcome | Partly allowed |
Outcome
Section 18 (complaint) and Section 19 (appeal) operate in different fields; Commission cannot order disclosure in a §18 complaint.
Ratio decidendi
The powers of the Commission under §18 (complaint) and §19 (appeal) are distinct. A complaint under §18 is meant for procedural grievances; substantive orders directing disclosure can be made only in an appeal under §19.
Keywords
§18, §19, complaint, appeal, Commission powers
Similar cases in the corpus
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- Police complaint records — Karnataka SIC (SIC-KA 2021)
- PIO silence as deemed refusal — Bombay HC (HC-BOM 2014)
- Whistleblower complaint anonymity — Delhi HC (HC-DEL 2019)
Related
Editorial summary, not a certified report. The ratio here is an editorial compression. Before citing this ruling in a PIO order, FAA speaking order, or any appellate filing, verify against the full reported decision. RTI Wiki is not a legal service.
Editorial summary · last reviewed 21 April 2026.
Discussion