Central Information Commission
Sutram Suresh vs Life Insurance Corporation Of India on 25 November, 2025
केन्द्रीय सूचना आयोग
Central Information Commission
बाबा गंगनाथ मागग, मुननरका
Baba Gangnath Marg, Munirka
नई निल्ली, New Delhi - 110067
File No: CIC/LICOI/A/2024/115780
Sutram Suresh .....अपीलकर्ाग /Appellant
VERSUS
बनाम
The PIO
LIC of India,
CRM Department
Division Office, JC Road
Bangalore-560002 ....प्रनर्वािीगण /Respondent
Date of Hearing : 24.11.2025
Date of Decision : 25.11.2025
INFORMATION COMMISSIONER : Vinod Kumar Tiwari
Relevant facts emerging from appeal:
RTI application filed on : 01.01.2024
CPIO replied on : 10.01.2024
First appeal filed on : 08.02.2024
First Appellate Authority's order : 27.02.2024
2nd Appeal/Complaint dated : 20.05.2024
Information sought:
1. The Appellant filed an RTI application dated 01.01.2024 (offline) seeking the following information:
"Agency code No. 05942611-Sutram Suresh-Documents showing the approval of the Disciplinary Authority obtained on the request dated 11.12.2023 made by the presenting officer, Smt Latha B.C. A.O.(SSS), LIC of India, Bangalore-DO-1, for providing letter Ref. DO1/Mktg. dated 12.03.2018 and my reply dated 28.06.2018."Page 1 of 11
CIC/LICOI/A/2024/115780
2. The CPIO furnished a reply to the Appellant on 10.01.2024 stating as under:
"The information sought by you regarding the documents showing the approval of the Disciplinary Authority obtained on the request dated 11.12.2023, is in nature of internal documents/correspondence and held by the Public Authority in fiduciary capacity and also disclosure of such information would endanger the life or physical safety of the third party and would also cause unwarranted invasion of their privacy. Hence we are unable to provide the information sought by you under Section 8 (1) (e), 8 (1) (j) and 8 (1) (g) of the RTI Act.
References:
CIC/LICOI/A/2021/124049-Sri Sunder Lal Vs CPIO, LIC, Karnal: The Commission observes that the information sought by the applicant is an internal document/correspondence and held by the public authority in fiduciary capacity. Therefore the same is exempted from disclosure under Sec 8 (1) (e) of the RTI Act.
CIC/LICOI/A/2021/102332- Sri Ravinder Chopra Vs CPIO, LIC, Delhi: The information sought are personal information related to third party which cannot be provided to the applicant and the disclosure of such information would endanger the life or physical safety of the their employee and would cause unwarranted invasion of their privacy. Therefore, the information sought cannot be provided as per Sec 8 (1) (j) & 8 (1) (g) of RTI Act."
3. Being dissatisfied, the Appellant filed a First Appeal dated 08.02.2025. The FAA vide its order dated 27.02.2024, held as under:
"The copies of letter Ref No: DO1/Mktg., dated 12.03.2018 and your reply letter dated 28.06.2018 were already provided to you during the disciplinary proceedings by the Presenting Officer vide Registered post dated 13.12.2023. On revisiting the records, it is informed that the approval for providing the above documents was accorded by the Senior Divisional Manager who is the Disciplinary Authority in this matter. The copy of the approval letter is an internal document not meant for outside circulation and hence cannot be provided.
It is further clarified that the Disciplinary Authority is the First Appellate Authority by virtue of his designation hence there is no violation of any principles of natural justice..."
4. Feeling aggrieved and dissatisfied, Appellant approached the Commission with the instant Second Appeal.
Page 2 of 11CIC/LICOI/A/2024/115780 Relevant Facts emerged during Hearing:
The following were present:-
Appellant: Present through video conference.
Respondent: Shri C R Aravind, Manager/CPIO along with Shri Bhaskar, Manager (Sales) and Shri Arvind Kumar, A.O. (Marketing) present through video conference.
5. Proof of having served a copy of Second Appeal on Respondent while filing the same in CIC on 20.05.2024 is not available on record. The parties confirmed non-service.
6. The Respondent submitted that their FAA, Shri P N Jha, Sr. Divisional Manager has filed a written submission dated 12.11.2025 enumerating the detailed facts of this case. A copy of which was already sent to the Appellant. He prayed the Bench to take it on record. Prayer allowed. Relevant extracts of the written submission are reproduced below for ready reference:
"...OUR WRITTEN SUBMISSION TO THE SECOND APPEAL:-
In the RTI stage since the applicant sought information of the documents showing the approval of the disciplinary authority obtained on the request dated 11.12.2023, CPIO replied that the information sought is in nature of internal documents/correspondence and held by the Public Authority in fiduciary capacity and also disclosure of such information would endanger the life of physical safety of the third party and would also cause unwarranted invasion of their privacy. Hence we are unable to provide the information sought by him under Section 8(1)(e),8(1)(j) and 8(1)(g) of the RTI Act. In reply to the Appeal, it was informed that the approval for providing the above said documents was accorded by the Senior Divisional Manager who is the Disciplinary Authority in this matter. The copy of the approval letter is an internal document not meant for outside circulation and hence cannot be provided. It is further clarified that the Disciplinary Authority is the First Appellate Authority by virtue of his designation, hance there is no violation of any principles of natural justice In reply to Second Appeal, we provide our written submission as follows: It is confirmed that approval was obtained from Disciplinary Authority in Senior Divisional Manager.Page 3 of 11
CIC/LICOI/A/2024/115780 Presenting Officer has obtained permission from Competent Authority for sharing of the said documents vide letter dated 11.12.2023 and the said documents were sent to the appellant by registered post on 13.12.2023. In First Appellate authority reply, we have informed regarding approval taken from Senior Divisional Manager, who is the Disciplinary Authority in the matter. It was Informed that copy of approval letter is an internal document, not meant for outside circulation, and hence was not provided to the appellant It was affirmed in the letter issued by Enquiry Officer vide letter dated 22.12.2023 confirming that the presenting officer obtained the approval of Disciplinary Authority as her request dated 11.12.2023 for providing copies of the two documents and also the reason for not providing the copy of approval considering that the same is not germane to the issue and is internal in nature.
Though in CPIO's reply dated 10.01.2024 information sought were exempted. under Section 8(1)(e),8(1)(0) and (1)(d), as the information sought is of fiduciary and personal information in nature, but in appeal stage, FAA informed that approval for providing the said documents was accorded by Sr. Divisional Manager who is the Disciplinary Authority in this matter to appellant vide reply dated 27.02.2024. However the copy of approval letter was not provided, as it is an internal document which is not meant for outside circulation. It was also clarified that Disciplinary Authority is the First Appellate Authority by virtue of his designation, hence it was reiterated that there is no violation of any principles of natural justice It was conveyed to the appellant vide letter dated 15.05.2024 regarding the mistake of providing the previous/earlier correspondence address of CIC in First Appellate Authority's order. The respondent office has completely admitted and accepted the mistake of not providing the latest address of CIC for which regrets and apology was sought. It was only human typographical error happened while drafting the reply, not done deliberately or intentionally. The correct/latest correspondence address was provided in the mentioned letter.
It is clarified that the said letters Ref: DO1/Mitg dated 12.03.2018 and the appellant reply dated 28.06.2018 which were relevant and pertinent to his cases were provided to the appellant vide letter sent by RPAD dated 13.12.2023 by Presenting Officer during Disciplinary Proceedings and also acknowledged by the appellant vide his letter dated 15.12.2023 (Annexure-M) noted in his second appeal.
Page 4 of 11CIC/LICOI/A/2024/115780 Since the said relevant documents were provided, the said approval letter was not provided by the Respondent office since it was not relevant to this case and is internal documents not meant for circulation, though the details of the Authority accorded permission to share the above said two letters were made known to the appellant in our reply to first appeal.
Now the matter was placed before special committee at Zonal office level and as per the advice of the committee the desired documents is being provided along with the written submission after applying severability clause as per Sec (10) of the RTI Act 2005.
In the light of the above, we humbly request the Hon'ble Chief Information Commissioner to dismiss summarily the second appeal dated 16.05.2024 filed by Sri Sutram Suresh."
7. On being queried by the Commission, the Appellant affirmed the receipt of requested information from the Respondent now vide averred written submission. He contested that there is an inordinate delay caused by the replying Respondents in furnishing the desired documents. He stated that he filed a written submission on the CIC's portal which may be considered for disposal of this Appeal. The written submission of the Appellant is taken on record. Contents of the same are reproduced below for reference:
"...Sir, I would like to bring to your kind notice here an update since I preferred Second Appeal before you on 16.05.2024 seeking the desired and required document. The enquiry proceedings in the matter of the Appellant as mentioned under 8. Brief facts leading to the Second Appeal (page no. 7 of Second Appeal) were abruptly concluded by the Enquiry Officer over 10 months ago on 06.01.2025 without even waiting for the outcome of this file No. CIC/LICOI/A/2024/115780 despite repeated requests from the Appellant in the proceedings seeking time with the Enquiry Officer to produce evidence against fresh charge under 16 (1) (d) levelled against the Appellant in the second show cause notice. Without fixing a date for hearing arguments by the Presenting Officer and Appellant, the Enquiry Officer concluded the enquiry which is unsustainable in the eyes of the law.
Following the Enquiry Officer's Report which dropped four out of the five regulations under LIC of India (Agents) Regulations, 2017 imposed on the Appellant in the second show cause notice including 16 (1) (d) (fails to furnish any Page 5 of 11 CIC/LICOI/A/2024/115780 information on relating to his activities as an Agent as required by the Corporation or the Authority), the Senior Divisional Manager (Disciplinary Authority) terminated my agency on 27.02.2025 with forfeiture of renewal commission based on a lone subjective Regulation 16 (1) (b) (acts in a manner prejudicial to the interests of the Corporation or to the interests of its policyholders) without proving or establishing the same. The matter is now in Appeal Stage before the Appellate Authority (Zonal Manager, LIC of India).
WRITTEN RESPONSE:
Review of Written Submission and the law:
1. The desired/ required document - Copy of the Approval letter dated 11/12/2023 with Severability clause - attached as Enclosure 6. with the Written Submission by the Senior Divisional Manager (SDM)/ First Appellate Authority (FAA), LIC of India, Bangalore Divisional Office-1 on the advice of the special committee at its Zonal office level SPEAKS OF CONFIRMATION OF A CLEAR EVIDENCE ON A FRESH CHARGE UNDER 16 (1) (d) LEVELED AGAINST THE APPELLANT IN THE SECOND SHOW CAUSE NOTICE and has brought down the curtain on contradicting and intriguing reasoning given hitherto at various stages by the Enquiry Officer, CPIO and FAA in that order in providing the same. ➢ Enquiry Officer: "... copy of the approval cannot be provided as the same is not germane to the issue and also as the same is internal in nature." (Annexure-N page no. 85 of Second Appeal).
➢ CPIO: "The information sought by you regarding the documents showing the approval of the Disciplinary Authority obtained on the request dated 11.12.2023 is in nature of internal documents/ correspondence and held by the Public Authority in fiduciary capacity and also disclosure of such information would endanger the life or physical 4 safety of the third party and would also cause unwarranted invasion of their privacy. Hence, we are unable to provide the information sought by you under Section 8 (1) (e), 8 (1) (j) and 8 (1) (g) of the RTI Act.
➢ References: CIC/LICOI/A/2021/124049 - Sri Sunder Lal Vs CPIO, LIC, Karnal CIC/LICOI/A/2021/102332 - Sri Ravinder Chopra Vs CPIO, LIC, Delhi" (Annexure-C page no. 16 of Second Appeal).
Page 6 of 11CIC/LICOI/A/2024/115780 ➢ FAA: "The copy of the approval letter is an internal document not meant for outside circulation and hence cannot be provided" (Annexure-E page no 26 of Second Appeal).
2. Also, the required document provided with this Written Submission, SPEAKS OF CONFIRMATION underlining the fact that the FAA, in his dual role as SDM, has deliberately dragged the Appellant's case to no end with a malicious intention to spoil a distinguished career that dates back to 1999 and trying to snatch the livelihood of an Agent in violation of Article 21 of the Constitution.
3. With this action of FAA, the second show cause notice dated 07.07.2023 (Annexure-H page nos. 32-34 of Second Appeal) issued under the directions of the Hon'ble High Court of Karnataka vide its order dated 02.03.2023 (AnnexureL page nos. 50-83 of Second Appeal) has now been rendered contradictory and meaningless and SPEAKS OF CONFIRMATION that this required document provided is "vital and germane to the second show cause notice".
4. Also, the required document provided SPEAKS OF CONFIRMATION about the enquiry proceedings initiated by the SDM as mere illegitimate, irrelevant, and timepass exercise, with both Enquiry Officer and Presenting Officer subjected to unwanted and unnecessary burden.
➢ The SDM first ignored the first limb of the Hon'ble High Court order (Annexure-L page no. 82 of Second Appeal) that had quashed both the orders of Disciplinary Authority dated 14.05.2019 and Appellate Authority dated 02.05.2020 and denied the Appellant to continue his LIC agency in terms of new business with scant regard for court order;
➢ then preferred to redo the entire exercise by issuing a second show cause notice to the Appellant as per the second limb of the Hon'ble High Court order (Annexure-at page no. 82 of Second Appeal) and went on to mention in the second show cause notice that "no reply was received from you (Appellant)" for the letter Ref: DO1/Mktg. dated 12.03.2018 sent by them and this amounts to violation under Regulation 16 (1) (d) of the Life Insurance Corporation of India (Agents) Regulations, 2017 (Annexure-H page no. 33 of Second Appeal); ➢ and called for Appellant's reply which was duly submitted on 27.07.2023 (Annexure-J page nos. 35-44 of Second Appeal);
➢ in which the Appellant had made it clear that he had submitted his reply on 28.06.2018 to the letter dated 12.03.2018 (Annexure-J page nos. 42-43 of Second Appeal).
Page 7 of 11CIC/LICOI/A/2024/115780 ➢ then appointed Enquiry Officer and Presenting Officer mentioning in their appointment letters (Annexure-K page nos. 46-47 of Second Appeal) that he is doing so in terms of powers conferred on him under the Fifth Schedule of the LIC of India (Agents) Regulations, 2017 and that the Appellant vide his REPLY dated 27.07.2023 to the Notice dated 07.07.2023 has not admitted to the charges mentioned in the Notice unconditionally, hence it has become necessary and expedient to enquire into the charges leveled against the Appellant. The second limb of the Hon'ble High Court's order (Annexure-L page no. 82 of Second Appeal) while remitting the matter back to the Disciplinary Authority (SDM) to redo the entire exercise from the stage of issuance of show cause notice to the petitioner (Appellant) had directed the Disciplinary Authority (SDM) to comply with the regulations (LIC of India Agents Regulations, 2017) and adhere to the observations made in the course of this order.
One such observation (Annexure-L page no. 72 of Second Appeal) reads: "a communication received by the petitioner (Appellant) from a person termed as Enquiry Officer on 14-09-2018 asking the petitioner to appear for personal hearing on 24-09-2018." This communication addressed to the Appellant and signed by the then Enquiry Officer confirms that LIC of India, Bangalore Divisional Office-1 have in their possession the Appellant's reply letter dated 28.06.2018. This communication reproduced in full in the court order, starts with the sentence, "We are in receipt of your letter dated 28-06-2018, requesting for reinstatement of agency and release of renewal commission ...". Thus it SPEAKS OF CONFIRMATION that the second show cause notice dated 07.07.2023 is a mere timepass exercise with a blatant lie having revolved just around this non- issue, without adhering to the observations made in the course of the Court order, accusing the Appellant of "no reply was received from you" and charging him under a fresh regulation 16 (1) (d).
The Fifth Schedule of the LIC of India (Agents) Regulations, 2017 which specifies the 14 procedures to be followed in that order while taking disciplinary action against the Agent provides absolutely no powers to the 6 SDM (Disciplinary Authority) to reverse the order of procedures involved. Initiating enquiry and issuance of show cause notice cannot be reversed. Moreover, the Hon'ble High Court order only directed the SDM to redo the entire exercise from the issuance of show cause notice only which was duly followed on 07.07.2023. The entire process should have been concluded after the Appellant's REPLY for the same dated 27.07.2023 with the SDM passing a final order with such decision as he deems fit. But what followed was illegitimate and now the orders of appointment Page 8 of 11 CIC/LICOI/A/2024/115780 of Enquiry Officer and Presenting Officer have now exposed the SDM/ FAA as a liar.
5. This action of FAA now has also resulted in highlighting one more observation in the Hon'ble High Court order with regard to earlier Final Order dated 14.05.2019 that "Charges were never framed against the Petitioner" (Annexure at page no. 78 of Second Appeal) and the same holds good even now for the second show cause notice dated 07.07.2023 issued following Court directions.
6. This Written Submission has exposed the FAA as incompetent as he had earlier denied document/ information sought without providing the Appellant an opportunity to be heard despite having prayed for the same; ignored the adoption of the Principle One of the principles of natural justice i.e., Nemo judex in causa sua; and judged a case in which he has an interest. The wiser counsel has now prevailed through the special committee at LIC's Zonal office level. I am only hoping "LET WISER COUNSEL PREVAIL AGAIN AT ZONAL OFFICE LEVEL"
as my Appeal for restoration of my agency is now before the Appellate Authority (Zonal Manager), LIC of India.
OBJECTION:
1.Whereas, I now strongly object to MASKING (REDACT) OF SIGNATURES in the required document provided with the Written Submission as the FAA has applied Severability clause as per Sec (10) of the RTI Act 2005 and has masked both his own signature in his capacity as SDM and Presenting Officer's signature. There are no grounds presented in doing so. Section 10 of the RTI Act which deals with Severability does not explicitly mention the "masking (redaction) of 7 signatures"
in its text. Section 10 focuses on the general principle of partial disclosure (severability), allowing public authorities to provide access to nonexempt parts of a record. It does not provide specific instructions on how to handle signatures. The practice of masking signatures, names, designations and other identifying information is based on the application of other exemption clauses within the Act
- primarily Section 8(1)(e) (fiduciary capacity), Section 8(1)(g) (physical safety) and Section 8(1)(j) (personal privacy) - as interpreted by various courts and Information Commission decisions. As claimed by CPIO none of the above apply in the case at lis (Annexure-C page no. 16 of Second Appeal). Thus, SDM's signature on an official document would likely to be deemed disclosable.
2. When the SDM, as an official of a statutory corporation wholly owned by the Government of India, can boldly sign the second show cause notice dated 07.07.2023 producing wrong facts/ blatant lies, imposing a fresh charge 16(1)(d) Page 9 of 11 CIC/LICOI/A/2024/115780 under the Agent's Regulations in lieu of an existing charge 16(1)(h) imposed earlier which was deleted without any explanation, why this preference to mask (redact) his own signature in the required document provided with this Written Submission that bears truth.
3. Also, I humbly submit that a document with masked signature provided under the RTI Act, only if duly certified by the competent Public Information Officer (PIO) with seal and signature, thus providing necessary legal sanctity, is generally considered a valid certified copy under the Indian Evidence Act, 1872 as only then the High Courts and Supreme Court flag them as proof of authenticity. Thus, kindly issue an order or direction to the CPIO in this regard." Decision:
8. The Commission after adverting to the facts and circumstances of the case, hearing the Respondent and perusal of the records observes that appropriate response has been provided by the Respondent earlier by the FAA and now vide written submission dated 12.11.2025, which serves the purpose of the Appellant of filing the instant RTI application in terms of the RTI Act.
9. Further, the Commission is not inclined to accept the contentions of the Appellant to initiate any penal action against the CPIO due to the fact that adequate reply has been given by the Respondent/ FAA and the Appellant has not served a copy of the instant Second Appeal upon the Respondent while filing the same before CIC. Moreover, the material fact has been suppressed by the Appellant that the information sought pertains to his own case. In the absence of which, plain reading of the RTI application indicated that the information sought pertains to third-party.
10. The Commission would like to remind the Appellant of the fact that serving a copy of documents (including Complaint and Second Appeal) to the opposite party is fundamental requirement for due process in legal proceedings and crucial for fairness, transparency, and also in the interest of expeditious response from the concerned Public Authority. It further reinforces the bonafide interest of the Appellant in obtaining the information at the earliest possible.
The requirement of advance service is in accordance with the audi alteram partem requirement. It further ensures that the opposite party is aware of the facts of filing of a case in CIC, arguments of the Appellant and reason for discontentment. It has been the experience that where the applicant had served advance copy of the Second Appeal/Complaint on the opposite party, the Page 10 of 11 CIC/LICOI/A/2024/115780 Respondent Public Authority has tried proactively to resolve the case by either providing clarity on the subject or by providing revised and updated reply/information to the Appellants before the matter reaches for the hearing. This ultimately results in faster delivery of information, thus, leading to a more efficient and effective Appeal disposal. It also reduces the time, energy and efforts of the Commission and Respondent Public Authority in early disposal. It is in his own interest for the Appellant/Complainant to serve copy of Second Appeal/Complaint on the Respondents.
11. Having observed as above, intervention of the Commission is not required in the matter.
The appeal is disposed of accordingly.
Vinod Kumar Tiwari (विनोद कुमार वििारी) Information Commissioner (सूचना आयुक्त) Authenticated true copy (अनिप्रमानणर् सत्यानपर् प्रनर्) (S. Anantharaman) Dy. Registrar 011- 26181927 Date Copy To:
THE FAA, LIC of India, CRM Department, Divisional Office JC Road, Bangalore-560002 Page 11 of 11 CIC/LICOI/A/2024/115780 Recomendation(s) to PA under section 25(5) of the RTI Act, 2005:-
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