Central Information Commission
Ashoka Samrat vs Unique Identification Authority Of ... on 25 May, 2026
CIC/UIDAI/C/2025/104444
के ीय सूचना आयोग
Central Information Commission
बाबा गंगनाथ माग,मुिनरका
Baba Gangnath Marg, Munirka
नई िद ी, New Delhi - 110067
िशकायत सं ा / Complaint No. CIC/UIDAI/C/2025/104444
Ashoka Samrat ...िशकायतकता/Complainant
VERSUS
बनाम
CPIO: Unique
Identification Authority of ... ितवादीगण /Respondents
India, (M/o. Electronics &
Information Technology-MeitY),
Hyderabad, Teleangana
Relevant dates emerging from the complaint:
RTI : 02.12.2024 FA : Not on record Complaint : 28.01.2025
CPIO : 03.01.2025 FAO : Not on record Hearing : 19.05.2026
Date of Decision: 21.05.2026
CORAM:
Hon'ble Commissioner
P R Ramesh
ORDER
1. The Complainant filed an RTI application dated 02.12.2024 seeking information on the following points:
1. Provide Photostat copy of license/certificate/Permission Letter/ authority/appointment letter of agency (ies) empanelled as enrolling agencies through an open Request for Empanelment (RFE) process by the Authority/Registrar has set up enrolment center in Tirupati (Torn & Rural) having Page 1 of 12 CIC/UIDAI/C/2025/104444 PIN Codes: 517501, 517502, 517503, 517504, 517506, 517507, after completing the requirement specifically eligibility, term and conditions, and other technical and financial criteria notified by the authority u/s 23 (1) of the Aadhaar (Enrolment and Update) Regulations Act 2016 to collect the both demographic and biometric information and other information related thereto from individuals who seek to enrol u/s 3, 4 and 5 of the Aadhaar (Enrolment and Update) Regulations Act 2016 to upload such enrolment packet to database called "Central Identities Data Repository" (CIDR) using the software provided by the Authority in electronic form for the purpose to issue Aadhaar letter to Aadhaar number holder and updating information of Aadhaar number holders under Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016.
2. Provide Photostat copy of license/certificate/Permission Letter/authority/appointment letter of agency (ies) empanelled as enrolling agencies appointed by the Authority/Registrar has set up enrolment centre in Tirupati (town & rural) having PIN Codes: 517501, 517502, 517503, 517504, 517506, 517507, after following a suitable process for screening u/s 23(5) of the Aadhaar (Enrolment and Update) Regulations Act 2016 to collect the both demographic and biometric information and other information related thereto from individuals who seek to enrol u/s 3, 4 and 5 of the Aadhaar (Enrolment and Update) Regulations Act 2016 to upload such enrolment packet to database called "Central Identities Data Repository" (CIDR) using the software provided by the Authority in electronic form for the purpose to issue Aadhaar letter to Aadhaar number holder and updating information of Aadhaar number holders under Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016..etc.
2. The CPIO replied vide letter dated 03.01.2025 and the same is reproduced as under:-
Page 2 of 12CIC/UIDAI/C/2025/104444
1. UIDAI appoints Central and State Government departments, special purpose vehicles created by them, public sector enterprises and banks and other regulated entities under regulation 21 ibid as Registrars. Registrar so appointed to submit a Terms of Engagement (TOC) duly signed by the authorized officer (Sample format of TE attached). Such Registrars, under regulations 23(5), 2(1)(1) 21(0) 23(8), 23(9), 23(10) and 25 of the Adhaar enrolment and update regulations can onboard themselves as an Enrolment Agency or can onboard any of its subordinate office/unit with the prior approval of UIDAI These Enrolling agencies set up enrolment centers to carry out the enrolment process while adhering to the processes and guidelines issued by UIDAI, through operators appointed by the enrolment agency, who are duly certified as per the certification process specified by UIDAI Hence, no separate agreements available with UIDAI
2. The details of Aadhaar enrolment centers along with name of agency is available at https://bhuvan-app3.nrsc.gov.in/aadhaar..
3. Only the document as specified by UIDAI shall be accepted by the operators to avoid further rejection of the request during process. List of valid documents available at https://uidai.gov.in/images/commdoc/List of Supporting Document for Aadhaar Enrolment a and Update.pdf.
4. Further it is to confirm that UIDAI website https://uidai.gov.in/en/ is fully functional..."
3. Dissatisfied with the response received from the CPIO, the Complainant filed a First Appeal. FAA vide order dated 26.02.2025 directed CPIO to furnish information in proper format.
4. In compliance of order of FAA, the CPIO furnished reply dated 03.03.2025 as under:
"..Your RTI application has been examined.Page 3 of 12
CIC/UIDAI/C/2025/104444 The grievance related information is - provided as below.
1. It is to confirm that UIDAI website https://uidai.gov.in/en/functional. is fully
2. The details of Aadhaar enrolment centres along with name of enrolment agency is available at https://bhuvan-app3.nrsc.gov.in/aadhaar/.
3. 3&4 Only the document as specified by UIDAI shall be accepted by the operators to avoid further rejection of the request during process. List of valid documents is available at https://uidai.gov.in/images/commdoc/Li st of Supporting Document for Aadh aar Enrolment_and_Update.pdf.
Further, the information as sought in RTI application is provided as below.
UIDAI appoints Central and State Government departments, special purpose vehicles created by them, public sector enterprises and banks and other regulated entities under regulation 21 ibid. as Registrars. Registrar so appointed to submit a Terms of Engagement (TOE) duly signed by the authorized officer (Sample format of TE attached). Such Registrars, under regulations 23(5), 2(1)(i), 2(1)(n), 23(8), 23(9), 23(10) and 25 of the Aadhaar enrolment and update regulations can onboard themselves as an Enrolment Agency or car onboard any of its subordinate office/urit with the prior approval of UIDAL. These Enrolling agencies set up enrolment centres to carry out the enrolment process while adhering to the processes and guidelines issued by UIDAI, through operators appointed by the enrolment agency, who are duly certified as per the certification process specified by UIDAI. Hence, no separate agreements available.."
5. Dissatisfied with the response received from the CPIO, the Complainant approached the Commission with the instant Complaint dated 28.01.2025.
Facts emerging in Course of Hearing:
Complainant: Not present Page 4 of 12 CIC/UIDAI/C/2025/104444 Respondent: Ms. K.M. Bharathi, Director - participated in the hearing through video- conference.
6. The Respondent while defending their case inter alia submitted that a point-wise reply has been duly provided to the Complainant. A written submission has been received from the CPIO in this regard and same has been taken on record for perusal. The relevant extract whereof is as under:
"..At the outset, it is respectfully submitted that the Reply dated 03.01.2025 furnished by the Central Public Information Officer (CPIO) was provided strictly in accordance with the provisions of the Right to Information Act, 2005 and the statutory framework governing Aadhaar enrolment and update processes under the Aadhaar (Targeted Delivery of Financial and Other Subsidies, Benefits and Services) Act, 2016 and the Aadhaar (Enrolment and Update) Regulations, 2016.
The Appellant has referred to various provisions of the Aadhaar Act and the associated regulations in the RTI application. For the assistance of the Hon'ble Commission, the relevant statutory position and the applicability of those provisions are explained below:
1. Institutional Framework under the Aadhaar Act:
The Unique Identification Authority of India (UIDAI) functions as the statutory authority responsible for policy formulation, standards and management of the Central Identities Data Repository (CIDR).
UIDAI onboards Registrars such as Central Government departments, State Government departments, banks, public sector undertakings and other authorised entities through Terms of Engagement (ToE). These Registrars may further onboard Enrolling Agencies to undertake enrolment and update activities in accordance with UIDAI guidelines.Page 5 of 12
CIC/UIDAI/C/2025/104444 The Enrolling Agencies establish enrolment centres and deploy operators, supervisors and verifiers. Operational records relating to appointment of operators, staff engagement, training records and other administrative documentation are therefore maintained by the concerned Registrar or Enrolling Agency.
2. Provisions of the Aadhaar Act cited by the Appellant:
The Appellant has referred to Sections 3, 4 and 5 of the Aadhaar Act, 2016.
Section 3 relates to the entitlement of a resident to obtain an Aadhaar number. Section 4 ceals with the use and authentication of the Aadhaar number, while Section 5 provides the broad framework governing enrolment and issuance of Aadhaar numbers.
These provisions establish the legal entitlement and enrolment framework but do not require UIDAI to maintain copies of appointment letters or staffing records of personnel working at enrolment centres operated by enrolling agencies.
3. Regulation 23 of the Aadhaar (Enrolment and Update) Regulations:
The RTI application refers to Regulation 23(1) and Regulation 23(5) of the Aadhaar (Enrolment and Update) Regulations, 2016.
Regulation 23(1) relates to the collection of demographic and biometric information from residents and the creation of enrolment packets for uploading to the CIDR. This provision concerns the procedural standards governing enrolment and does not deal with staffing or administrative records of enrolment centres.
Regulation 23(5) enables Registrars to onboard Enrolling Agencies for carrying out enrolment activities. These agencies operate enrolment centres, deploy operators and supervisors and maintain operational documentation.Page 6 of 12
CIC/UIDAI/C/2025/104444 Accordingly, appointment letters. staffing records and internal administrative arrangements are maintained by the respective Registrar or Enrolling Agency.
4. Regulation 24-Engagement of Service Providers:
The RTI application seeks photocopies of appointment letters of service providers referred to under Regulation 24.
Regulation 24 permits engagement of service providers for certain technical or operational functions within the enrolment ecosystem. Such engagements are generally undertaken through contractual arrangements between Registrars or Enrolling Agencies and their service providers.
UIDAI does not ordinarily maintain individual appointment letters or employment records of personnel deployed by such service providers at local enrolment centers 5. Regulation 25-Operators, Supervisors and Verifiers:
The Appellant has also referred to Regulation 25 which provides that operators and supervisors engaged in the enrolment process must be trained and certified in accordance with the certification framework prescribed by UIDAI.
While UIDAI prescribes the certification standards, the deployment and employment records of operators, supervisors and verifiers are maintained by the respective Enrolling Agencies or Registrars.
6. Applicability of Section 2(f) of the RTI Act:
Under Section 2(f) of the Right to Information Act, 2005, information refers to material held by or under the control of the public authority.
The RTI application seeks photocopies of appointment letters of operators, appointment records of supervisors and verifiers, staff training certificates and other operational documents relating to enrolment centres.Page 7 of 12
CIC/UIDAI/C/2025/104444 Such documents are generally maintained by the Registrars or Enrolling Agencies and are not part of the records maintained by UIDAI in the normal course of its regulatory functions. Accordingly, the information sought does not fall within the scope of information held by the respondent public authority.
7. Exemptions under Section 8 of the RTI Act:
Certain information sought by the Appellant relates to appointment records of individuals and internal operational arrangements of enrolling agencies. Disclosure of such information may attract the provisions of Section 8(1)(d) relating to commercial confidence and contractual arrangements of third party agencies, Section 8(1)(e) relating to information available in fiduciary capacity, and Section 8(1)(j) relating to personal information of individuals such as operators, supervisors and staff.
8. Centre Address and Supporting Documents:
It is respectfully submitted that a substantial portion of the RTI application seeks detailed address wise information of Aadhaar enrolment centres operating in Tirupati Town and surrounding PIN codes, along with particulars relating to operators, their appointment, certification, skill, knowledge and capability to perform enrolment functions.
A careful reading of the RTI application along with the supporting documents and references to earlier Circular dated 2019 indicates that the information sought is more in the nature of personal grievance relating to the expansion of initials or surname in the Aadhaar record than Public information.
Earlier, in certain cases, residents attempted demographic updates such as expansion of initials on the basis of certificates issued by Gazetted Officers. However, over time it has been observed that the authenticity of such certificates could not always be independently verified within the Aadhaar Page 8 of 12 CIC/UIDAI/C/2025/104444 update ecosystem. Accordingly, the practice of accepting such certificates for demographic updates was discontinued and only the officially notified list of valid supporting documents is presently accepted for Aadhaar enrolment and update purposes.
time and the relevant i.e. The list of valid supporting documents is publicly notified by UIDAI from time to link, https://uidai.gov.in/images/commdoc/List of Supporting Document for Aadhaar Enrol ment_and Update.pdf had also been shared with the Appellant by CPIO in the reply sent.
It is further submitted that information relating to active Aadhaar enrolment centres is already available in the public domain through the "Bhuvan Aadhaar" portal maintained by UIDAI. The portal provides near real-time information on active Aadhaar enrolment and update centres across the country and allows users to search for centres at State, District and PIN Code levels.
Therefore, information regarding the location of enrolment centres in Tirupati, including the PIN Codes referred to by the Appellant, is readily accessible through the said portal.
9. Clarification regarding UIDAI Website:
The Appellant has also made a general allegation that the UIDAI website is not functioning. In this regard, it is respectfully submitted that the UIDAI website and associated public service portals remain operational and accessible. Any temporary difficulty in accessing the website may arise due to local connectivity issues or device specific technical conditions and cannot be construed as non-availability of the service itself. The CPIO had categorically informed the Appellant regarding the smooth functioning of the website.
10. Good Faith Action by the CPΙΟ:
Page 9 of 12CIC/UIDAI/C/2025/104444 It is respectfully submitted that the CPIO responded to the RTI application in good faith and in accordance with the provisions of the RTI Act. The reply was based on the information available with the public authority and there was no malafide denial of information.
Further it is humbly submitted that the Reply issued by the CPIO is strictly in consonance with the Para 10 of the Guide 33 on the Right to Information Act 2005 circulated vide DOPT O.M. No.1/4/2009-IR dated 05.10.2009 and the ruling in Central Board of Secondary Education & Anr. Vs. Aditya Bandopadhyay & Ors. (Civil Appeal No.6454 of 2011) Prayer: In view of the above submissions, it is humbly prayed to the Hon'ble Commission that the information sought is either not held by the Respondent public authority and/or is exempt from disclosure under the provisions of the RTI Act. Hence, may kindly take the above submissions on record and dispose of the appeal accordingly..."
Decision:
7. At the outset, Commission directs the concerned PIO to furnish a copy of their latest written submission dated 10..04.2026 along with annexures if any, to the RTI Applicant, free of cost via speed-post and via e-mail, within 07 days from the date of receipt of this order and accordingly, compliance report be sent to the Commission.
8. Commission has gone through the case records and on the basis of proceedings during hearing observes that appropriate reply has been provided to the Complainant by the CPIO as per the provisions of the RTI Act. Therefore, no malafide can be ascribed over the conduct of the CPIO and thus, no penal action is warranted in the matter.
9. Commission further observes that the Complainant has chosen to approach the Commission with a Complaint under Section 18 of the RTI Act wherein the Commission is required to examine whether there was any deliberate denial of information by the public authority. It is worthwhile to place reliance on the judgment of the Hon'ble Supreme Court Page 10 of 12 CIC/UIDAI/C/2025/104444 of India in the case of Chief Information Commissioner and Another v. State of Manipur and Anr. in Civil Appeal Nos. 10787-10788 of 2011 dated 12.12.2011, relevant extract whereof is as under:
"...28. The question which falls for decision in this case is the jurisdiction, if any, of the Information Commissioner under Section 18 in directing disclosure of information. In the impugned judgment of the Division Bench, the High Court held that the Chief Information Commissioner acted beyond his jurisdiction by passing the impugned decision dated 30th May, 2007 and 14th August, 2007. The Division Bench also held that under Section 18 of the Act the State Information Commissioner is not empowered to pass a direction to the State Information Officer for furnishing the information sought for by the complainant."
"30. It has been contended before us by the Respondent that under Section 18 of the Act the Central Information Commission or the State Information Commission has no power to provide access to the information which has been requested for by any person but which has been denied to him. The only order which can be passed by the Central Information Commission or the State Information Commission, as the case may be, under Section 18 is an order of penalty provided under Section 20. However, before such order is passed the Commissioner must be satisfied that the conduct of the Information Officer was not bona fide."
31. We uphold the said contention and do not find any error in the impugned judgment of the High court whereby it has been held that the Commissioner while entertaining a complaint under Section 18 of the said Act has no jurisdiction to pass an order providing for access to the information."
"37. We are of the view that Sections 18 and 19 of the Act serve two different purposes and lay down two different procedures and they provide two different remedies. One cannot be a Substitute for the other...."Page 11 of 12
CIC/UIDAI/C/2025/104444
10. Thus, the limited point to be adjudicated in complaint u/s 18 of RTI Act is whether the information was denied intentionally.
11. In the light of the above observations, the Commission is of the view that there is no malafide denial of information on the part of the concerned CPIO and hence no action is warranted under section 18 and 20 of the Act. The Complaint is disposed of accordingly.
Sd/-
(P R Ramesh) (पी. आर. रमेश) Information Commissioner (सू चना आयु ) Authenticated true copy Vivek Agarwal (िववेक अ वाल) Dy. Registrar (उप पंजीयक) 011-26107048 Addresses of the parties:
1 The CPIO Director & CPIO, Unique Identification Authority of India, (M/o. Electronics & Information Technology-MeitY), R.O.--605-612, 6th Floor, Swarna Jayanti Comm. Complex, Ameerpet, Hyderabad-500038 (Telangana).
2 Ashoka Samrat Page 12 of 12 Recomendation(s) to PA under section 25(5) of the RTI Act, 2005:-
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