The Lift Line
“The efficient implementation of Section 4 can not only improve transparency but also reduce the pendency piling up with the CIC and State Information Commissions.” (Sneha Gandla, Gauri Singavarapu and Sachin Swaraj, The Hindu, 12 October 2026)
Why This Editorial Matters for Your Exam
The Hindu marks the 21st anniversary of the Right to Information (RTI) Act on 12 October 2026 with a data analysis, “The gaps in the implementation of the RTI Act”, by Sneha Gandla, Gauri Singavarapu and Sachin Swaraj. Their focus is not the RTI request that most aspirants know about, but Section 4, the duty of every public authority to publish information suo motu, without being asked. Their finding: “An analysis, however, showed that such voluntary disclosure has not been followed.”
For the exam, this piece supplies three things that are rarely in one place: the statutory text of Section 4, the audit system that DoPT built around it, and the latest numbers from the Central Information Commission (CIC) Annual Report 2024-25. All three are ready material for a GS2 answer on transparency and accountability.
GS Paper 2: transparency and accountability; the RTI Act; statutory bodies (the Central and State Information Commissions); e-governance and citizen charters.
In the news: in a data analysis published as the Act completed 21 years (The Hindu, 12 October 2026), three analysts find that proactive disclosure under Section 4 of the RTI Act lags. The CIC Annual Report 2024-25 shows that only 1,446 of 2,303 public authorities registered with the Commission sent third-party transparency audit reports, and 783 of these were graded C, D or E. The authors’ own check found 2024-25 audit reports on only 33 of 94 department websites.
Background and Context
The Act in brief
| Item | Fact |
|---|---|
| Statute | The Right to Information Act, 2005 (Act No. 22 of 2005), assented to on 15 June 2005 |
| Commencement | Under Section 1(3), Section 4(1), Section 5(1) and (2) and Sections 12, 13, 15, 16, 24, 27 and 28 came into force at once; “the remaining provisions of this Act shall come into force on the one hundred and twentieth day of its enactment”, that is, on 12 October 2005 |
| Reporting | Section 25(1): the Central or State Information Commission prepares, after each year, “a report on the implementation of the provisions of this Act during that year” and forwards it to the appropriate Government. The CIC Annual Report 2024-25 is this report |
| Amendments | The RTI (Amendment) Act, 2019 (24 of 2019), in force from 24 October 2019: the Central Government now prescribes the term of office, salaries and other conditions of service of the Chief Information Commissioner and Information Commissioners; the Act earlier set a term of five years. The Digital Personal Data Protection Act, 2023 (Section 44) substituted Section 8(1)(j), from 13 November 2025, to read “information which relates to personal information” |
What Section 4 asks of every public authority
| Provision | Duty |
|---|---|
| 4(1)(a) | Maintain all records “duly catalogued and indexed”, and computerise those appropriate to be computerised, connected through a network |
| 4(1)(b) | Publish seventeen heads of information, from “(i) the particulars of its organisation, functions and duties” to “(xvi) the names, designations and other particulars of the Public Information Officers”, with (xvii) “such other information as may be prescribed”; publish “within one hundred and twenty days from the enactment of this Act” and “thereafter update these publications every year” |
| 4(1)(c) | “publish all relevant facts while formulating important policies or announcing the decisions which affect public” |
| 4(1)(d) | “provide reasons for its administrative or quasi-judicial decisions to affected persons” |
| 4(2) | “It shall be a constant endeavour of every public authority to take steps in accordance with the requirements of clause (b) of sub-section (1) to provide as much information suomotu to the public at regular intervals through various means of communications, including internet, so that the public have minimum resort to the use of this Act to obtain information.” |
| 4(3) | “every information shall be disseminated widely and in such form and manner which is easily accessible to the public” |
| 4(4) | Dissemination should take into account “the cost effectiveness, local language and the most effective method of communication in that local area” |
The authors write that Section 4(1)(b) lists “16 types of information”. The statute has seventeen clauses; the count of sixteen leaves out the last one, (xvii), which is a residual head for whatever the government prescribes.
How compliance is checked: the transparency audit
| Date | Step |
|---|---|
| 15 April 2013 | DoPT issues guidelines on suo motu disclosure under Section 4 (Office Memorandum No. 1/6/2011-IR) |
| 7 November 2019 | The guidelines are reiterated; Para 4.4 provides that each Ministry or public authority “should get its proactive disclosure package audited by third party every year”, and the audit is to be communicated to the CIC annually |
| 2019-20 | The CIC builds dedicated software to receive the audit reports |
| 14 September 2022 | DoPT reminds Ministries: “out of 2275 Public Authorities registered with CIC, only 754 of them have been reported to get their proactive disclosure audited” in 2020-21, which “has been viewed seriously by the Govt.”; the Department Related Parliamentary Standing Committee “raised concern over the poor implementation” |
The audit may be given to the training institute under each Ministry, Department or public authority; where none exists, to any government training institute.
The 2024-25 grades
| Grade | Public authorities | Share of the 1,446 |
|---|---|---|
| A | 410 | 28.4% |
| B | 253 | 17.5% |
| C | 302 | 20.9% |
| D | 215 | 14.9% |
| E | 266 | 18.4% |
| Total | 1,446 | 100% |
Source: CIC Annual Report 2024-25, section 3.5.2. The shares are our calculation. The authors explain the scale as follows: Grade C or below means a score of 80% or below in the audit, and Grade E a score below 60%.
The Analysis
1. Disclosure first, requests second. The Act was designed so that most information would already be in the public domain. Section 4(2) asks every public authority to publish so much on its own that “the public have minimum resort to the use of this Act to obtain information”. The authors make the same point: suo motu disclosure exists “so that people do not have to resort to filing requests under the Act for accessing basic information regarding any department.”
2. Nearly four in ten did not file. According to the CIC’s annual report, of the 2,303 public authorities registered with the Commission, 1,446 sent audit reports for 2024-25, about 63 per cent. The other 857, nearly 37 per cent, did not. Every one of the 2,303 filed its annual return to the Commission that year; the audit, by contrast, is where the gap opens.
3. Most of those audited scored low. Of the 1,446 that filed, 783, or about 54 per cent, were graded C, D or E. Only 410 reached Grade A.
4. The trend is upward. In 2020-21, according to DoPT’s memorandum, only 754 of 2,275 registered public authorities were reported to have had their disclosure audited. By 2024-25, 1,446 sent audit reports, nearly twice as many. The authors read the five-year trend as showing that “the compliance has improved year-on-year”.
5. What the websites show. The authors checked the websites of the 94 departments under which these public authorities fall. In their analysis, only 33 had audit reports for 2024-25; 56, or about 60 per cent, had complied with Section 4 on most categories with information from 2025-26; 26 did not have the information covered under the Act; and for the Ministry of Social Justice and Empowerment “there was no information available”. The DoPT guidelines, they note, recommend uploading the audit reports on the websites.
6. The cost of not disclosing. When information is not published, citizens file requests, and refusals become appeals. The registered public authorities received 17,95,024 RTI requests in 2024-25, according to the CIC’s annual return summary. The Commission disposed of 19,415 second appeals and complaints in the year; for context, 23,146 were pending on 1 April 2025. The authors argue that better Section 4 compliance would reduce “the pendency piling up with the CIC and State Information Commissions.”
7. A duty without a penalty. The Act’s penalty clause, Section 20, lets an Information Commission fine a Public Information Officer two hundred and fifty rupees a day, up to twenty-five thousand rupees, for lapses on a request: refusing an application, delaying or denying information without reasonable cause, or giving misleading information. Its triggers all concern a request. The column does not make this point, but it helps explain the gap: Section 4 relies instead on guidelines, audits and reminders, so compliance has depended on administrative push.
Data and Institutions Vault
Prelims-grade facts:
- RTI Act, 2005: Act No. 22 of 2005; assent 15 June 2005; Section 4(1) in force at once, remaining provisions on the 120th day of enactment.
- Section 4(1)(b): seventeen heads, the last, (xvii), residual; publish within 120 days of enactment and update every year.
- Section 4(2): publish suo motu so that the public have “minimum resort to the use of this Act”.
- Section 25: each Information Commission sends a yearly implementation report to the appropriate Government.
- DoPT O.M. No. 1/6/2011-IR: guidelines of 15 April 2013, reiterated 7 November 2019; Para 4.4 asks for a third-party audit every year.
- 2024-25: 1,446 of 2,303 registered public authorities sent audit reports; Grade A 410, B 253, C 302, D 215, E 266.
- 2020-21: 754 of 2,275 registered public authorities had their disclosure audited.
- CIC pendency: 23,146 second appeals and complaints pending on 1 April 2025.
- Section 20: penalty of Rs 250 a day, up to Rs 25,000, on a Public Information Officer for lapses on a request.
- 2019 Amendment: term and salaries of Information Commissioners to be prescribed by the Central Government (from 24 October 2019).
⚠️ Watch the trap: Section 4(1)(b) has seventeen clauses, not sixteen; the last is residual. And 56 of 94 websites is about 60 per cent, not 62.
The Debate
The authors’ case. Section 4 was meant to be the Act’s first line of service, and it is not being honoured. Too many public authorities do not file their transparency audit at all; most of those that do score in the lower grades; and many department websites lack basic information or carry old reports. Better proactive disclosure would serve citizens directly and would also cut the appeals that clog the Information Commissions.
The other side. The audit measures filing and form, not whether citizens find the information useful; a perfect score does not mean a usable website. The numbers are also moving the right way: audit returns have nearly doubled in four years under the existing guidelines, without any change in law. And some heads of Section 4(1)(b), such as the monthly remuneration of each officer, need care so that disclosure sits well with the personal-information exemption in Section 8(1)(j), recast by the DPDP Act passed in 2023 and in force from 13 November 2025.
The balanced verdict. The authors are right that Section 4 is the weaker half of the Act and that its neglect shows up later as pendency. The fix need not be punitive. Making every audit and its grade public, holding departments to the yearly update the statute already requires, and having the Commissions review Section 4 compliance alongside appeals would give the guidelines the visibility they now lack.
How to Think About This
Use a supply and demand lens for transparency. Supply is what government publishes unasked under Section 4; demand is what citizens must request. When supply falls, demand rises, and every refusal becomes an appeal. So the CIC’s pendency of 23,146 is not only a capacity problem in the Commission; it is also a symptom of disclosure failures upstream. In an answer, pair one supply-side reform (published audits, yearly updates, local languages) with one demand-side reform (faster appeal disposal) to show you see both ends.
Diagram-in-Words
Section 4 of the RTI Act: the duty and the gap
From the statute to the audit numbers and the pendency that follows.
The figure below traces Section 4 from the statute to the audit numbers and the pendency that follows when disclosure fails.
Takeaway Box
- Section 4 of the RTI Act obliges public authorities to publish information suo motu, updated every year.
- DoPT guidelines (2013, reiterated 2019) require a third-party transparency audit every year, reported to the CIC.
- In 2024-25, 1,446 of 2,303 registered public authorities sent audit reports; 783 of them were graded C, D or E.
- The authors’ website check: 2024-25 audit reports on only 33 of 94 department websites.
- Better disclosure would reduce pendency: 23,146 second appeals and complaints were pending with the CIC on 1 April 2025.
Revision Flowchart
RTI Act Gaps: Section 4 Disclosure and Transparency Audits
Covers the terms, Prelims pointers and traps, Mains pointers, the way forward and a practice question.
Sources: The Hindu, “The gaps in the implementation of the RTI Act”, data analysis by Sneha Gandla, Gauri Singavarapu and Sachin Swaraj, 12 October 2026 (print); The Right to Information Act, 2005, as amended in 2019 and by the DPDP Act, 2023, text as on 18 November 2025 (Sections 1, 4, 8, 13, 20, 25); DoPT Office Memorandum No. 1/6/2011-IR, 14 September 2022; Central Information Commission, Annual Report 2024-25
Source: RTI Act Gaps: Section 4 Disclosure and Transparency Audits — Ujiyari.com | Free UPSC & State PCS Editorial Analysis
