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Central Information Commission

Natraj Ramaswamiah Gubbi vs Rural / Gramin Banks on 13 June, 2025

                                    के ीय सूचना आयोग
                            Central Information Commission
                                 बाबा गं गनाथ माग,मुिनरका
                             Baba Gangnath Marg, Munirka
                               नई िद   ी, New Delhi - 110067
ि तीय अपील सं       ा / Second Appeal No. CIC/RUGBK/A/2024/602542+
                                        CIC/RUGBK/A/2024/603300

 Natraj Ramaswamiah Gubbi                                      ... अपीलकता/Appellant

                                       VERSUS
                                        बनाम
 CPIO:
 Himachal Pradesh Gramin Bank,                             ... ितवादीगण/Respondent
 Mandi, Himachal Pradesh

Relevant dates emerging from the appeal(s):

 RTI : 11.08.2023              FA      : 21.10.2023            SA     : 25.11.2023

 CPIO : 04.09.2023             FAO : 23.11.2023                Hearing : 04.06.2025
Note: The above referred appeal(s) have been clubbed for decision as these relate to
RTI Applications based on the same subject matter.

Date of Decision: 13.06.2025

                                        CORAM:
                                  Hon'ble Commissioner
                                _ANANDI RAMALINGAM
                                       ORDER

Second Appeal No. CIC/RUGBK/A/2024/602542

1. The Appellant filed an RTI application dated 11.08.2023 seeking information on the following points:

"In continuation of my earlier request for information pertaining to final orders of Disciplinary Authority dated 13.07.2023 served to Natraj Ramaswamiah Gubbi, it is my humble request to you for providing following additional documents which are required Page 1 of 9 for drafting of my appeal to Appellate Authority against final orders of Disciplinary Authority. List of documents required:
1) Attested copy of all correspondence mails / letters between Head Office / Regional Office Mandi and Branch office Nagwain (8720) which are related to Natraj Ramaswamiah Gubbi during the period 01.02.2023 to 13.07.2023
2) Attested copy of internal committee office note prepared for recommending suspension of Natraj Ramaswamiah Gubbi vide suspension order dated 15.02.2023.

3) Attested copy of internal committee office note prepared for rejection of VRS applied by Natraj Ramaswamiah Gubbi vide his request letter dated 14.02.2023.

4) Attested copy of letter of rejection of application of VRS given to Natraj Ramaswamiah Gubbi with date of dispatch and postal receipt.

5) Attested copy of attendance register of branch office Bahang (8825) for the months of April 2017, May 2017, June 2017 and July 2017...."

1.1. The CPIO replied vide letter dated 04.09.2023 and the same is reproduced as under:-

"1. Copy of all correspondence mails/letters done with you related to you during the period of 01.02.2023 to 13.07.2023 has been enclosed. (Pages 1-14)
2. Copy of internal committee note prepared for suspension cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(j) of the RTI act. 2005.
3. Copy of internal committee note prepared for rejection of VRS cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(j) of the RTI acı. 2005.
4. Copy of letter of rejection of application of VRS given to you has been enclosed with date of dispatch and postal receipt (Pages 15).
Page 2 of 9
5. Copy of attendance register of Branch Office Bahang for the period of April 2017 to July 2017 has been enclosed. (Pages 17-24)..."

1.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeals dated 21.10.2023. The FAA vide order dated 23.11.2023 stated that:

"Sr No. 2: Copy of internal committee note prepared for suspension cannot be provided as it is for internal purpose only and cannot be divulged under Section 8(1)(j) of the RTI Act, 2005.
Sr No. 3: Copy of internal committee note prepared for rejection of VRS cannot be provided as it is for internal purpose only and cannot be divulged under Section 8(1)(j) of the RTI Act, 2005.
1.3. Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 25.11.2023.
Second Appeal No. CIC/RUGBK/A/2024/603300
2. The Appellant filed an RTI application dated 11.08.2023 seeking information on the following points:
"It is my humble request to you for providing following documents which are required for drafting of my appeal to Appellate Authority against final orders of Disciplinary Authority dated 13.07.2023 served to undersigned. List of documents required:
1) Copy of vigilance document / Manual of Himachal Pradesh Gramin Bank regarding detailed guidelines for conducting inquiry proceedings against staff of the bank.
2) Copy of complaint received against Natraj Ramaswamiah Gubbi regarding irregularities at Branch Office Nagwain.
3) Copy of the minutes of Internal Committee for ordering of investigation of complaint against Natraj Ramaswamiah Gubbi regarding irregularities at Branch Office Nagwain.
Page 3 of 9
4) Copy of orders of competent authority for instituting investigation of the complaint against Natraj Ramaswamiah Gubbi regarding irregularities at Branch Office Nagwain.
5) Copy of the detailed report submitted by investigating officer of the complaint against Natraj Ramaswamiah Gubbi regarding irregularities at Branch Office Nagwain...." etc.

2.1. The CPIO replied vide letter dated 04.09.2023 and the same is reproduced as under:-

"1. Chapter-IV. Conduct, Discipline and Appeals of Himachal Pradesh Gramin Bank Service Regulationl 2010 has been enclosed. (Pages 1-102.
2. Copy of complaint cannot be provided as it is for internal correspondence and contents of same cannot be divulged to you as per section 8 (1)(g) & (h) of the RTI act. 2005.
3. Copy of the Minutes of Internal Committee for ordering of Investigation of complaint "against you cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(h) of the RTI act. 2005.
4. Copy of orders of competent authority for instituting investigation of the complaint against you cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(h) of the RTI act. 2005.
5. Same as point no. 4..."

etc. 2.2. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeals dated 21.10.2023. The FAA vide order dated 23.11.2023 stated that:

Page 4 of 9
"Sr No. 2: Copy of complaint cannot be provided as it is for internal correspondence and contents of same cannot be divulged to you as per section 8 (1)(g) & (h) of the RTI act, 2005.
Sr No. 3: Copy of the Minutes of Internal Committee for ordering of Investigation of complaint against you cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(h) of the RTI act, 2005.
Sr No. 4: Copy of orders of competent authority for instituting investigation of the complaint against you cannot be provided as it is for internal purpose only and cannot be divulged under section 8(1)(h) of the RTI act, 2005 Sr No. 5: Same as point no. 4..." etc. 2.3. Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated 25.11.2023.
Hearing Proceedings & Decision:
3. The appellant and on behalf of the respondent Rajiv Ranjan, General Manager, attended the hearing through video conference.
4. The appellant, in case no. CIC/RUGBK/A/2024/602542, contended that the CPIO had wrongfully denied the information sought under points 2 and 3 of his RTI application by invoking Section 8(1)(j) of the RTI Act. Further, in case no. CIC/RUGBK/A/2024/603300, the appellant expressed dissatisfaction with the denial of information pertaining to points 2 to 9 and 14 to 16 of his RTI application.
5. The respondent while defending their position in case no. CIC/RUGBK/A/2024/602542, reiterated the contents of their earlier reply dated 04.09.2023 and submitted that the internal committee notes sought by the appellant contained names and other details of the officials who were part of the committee. Accordingly, the information was denied under Section 8(1)(j) of the RTI Act. With respect to case no. CIC/RUGBK/A/2024/603300, the respondent reiterated the contents of Page 5 of 9 their written submissions dated 02.06.2025 concerning points 2 to 9 and 14 to 16 of the RTI application. The relevant portion of which is as follows "Sr. no. 2: That as the complaint sought by the applicant was instituted under the whistleblower act the same cannot be divulged it is a third party information and cannot be divulged as per section 8(1)(g) & (j) of the RTI Act, 2005.
Sr. no. 3: That information sought pertains to the internal committee proceedings related to confidential information and disclosure may endanger the safety of individuals involved. Hence the request is denied as per section 8(l)(g) and 8(l)(h) of the RTI act, 2005 Sr. no. 4: That as the investigation was initiated on the basis of a confidential complaint its disclosure may endanger the safety or identity of the source. Hence the same cannot be provided as per section 8(l)(g) & (j) of the RTI act, 2005.
Sr. no. 5: The copy of the detailed report submitted by the investigating officer regarding the irregularities have already been provided to the applicant at the time of investigation.
Sr. no. 6: That information sought pertains to the investigation related to confidential information and disclosure may endanger the safety of individuals involved. Hence the request is denied as per section 8(1)(g) and 8(l)(h) of the RTI act, 2005.
Sr. no. 7: That information sought pertains to the investigation related to confidential information and disclosure may endanger the safety of individuals involved. Hence the request is denied as per section 8(l)(g) and 8(l)(h) of the RTI act, 2005. It is also submitted that the chargesheet submitted to the applicant also incorporated the views of the vigilance officer included by him in the first stage advise.
Sr. no. 8: That as the advice was given on the basis of the whistleblower complaint disclosure may endanger the safety of individuals involved and is for internal circulation only. Hence the same is denied under section 8(1)(g) & G) of the RTI act, 2005. It is also submitted that the chargesheet submitted to the applicant also incorporated the views of the vigilance officer included by him in the first stage advise.
Sr. no. 9: That the information sought is for internal circulation only the same is denied under section 8(1)0) of the RTI act, 2005.
Page 6 of 9
Sr. no. 14: Copy of recording of CCTV footage of BO Nagwain cannot be provided as it would directly impact the security of the Bank and hence cannot be divulged to you as per section 8 (l)(g) of the RTI act, 2005.
Sr. no. 15 & 16: Copy of recording of CCTV footage of RO Mandi for the said period cannot be provided as it would directly impact the security of the bank and hence cannot be divulged to you as per section 8 (l)(g) of the RTI act, 2005."

6. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes in CIC/RUGBK/A/2024/602542 that since the information sought for in the RTI Application at points 2 & 3 relate to the case of suspension and VRS of the Appellant himself, the invocation of Section 8(1)(j) is incorrect and inappropriate, particularly, when the justification for the same is that the record is for internal purpose. The CPIO shall note that "internal purpose" is not an exemption prescribed under the RTI Act. Moreover, the square denial of the said information citing any of the Section 8 exemptions does not appear to be viable, as such. Now, therefore, the CPIO is directed to provide the information sought under points 2 and 3 of the RTI application to the Appellant incorporating the available information. While doing so, the CPIO is at liberty to redact the names and identifying particulars of third parties, if any, figuring in the relevant records, that stand exempted as per Section 8(1)(j) & 8(1)(g) of the RTI Act. The redaction of records shall be carried out in consonance with Section 10 of the RTI Act.

7. In CIC/RUGBK/A/2024/603300, the Commission finds that the response furnished to the RTI application is largely appropriate, except with respect to points 3 to 9. With specific reference to point 5, the Commission notes that the respondent's assertion--that the information has already been provided to the appellant outside the RTI framework-- is not tenable. Under the provisions of the RTI Act, the CPIO is under a statutory obligation to respond to each query strictly within the scope of the Act, either by providing the information available on record or by denying it through a reasoned response under Sections 8 or 9, citing valid exemption clauses.

Page 7 of 9

With respect to points 7 and 8, the Commission notes that the CPIO squarely denied the information under Sections 8(1)(g), (h), and (j), while simultaneously stating that the same information is incorporated in the chargesheet submitted to the appellant. This renders the denial absurd. Furthermore, the sum and substance of the RTI application indicates that the appellant has sought records relating to a disciplinary inquiry initiated against him and the same cannot be squarely denied to him citing one or the other exemptions of Section 8 without any apparent or justified square applicability. In light of the same, the Commission directs the CPIO to furnish a revised response on points 3 to 9, ensuring that the sought information pertaining to the appellant's own disciplinary proceedings are disclosed. While disclosing such information, the CPIO is at liberty to redact the names and identifying particulars of third parties as well as such other contents that may endanger the life or physical safety of any person or identify the source of information. The redaction of the records shall be carried out in accordance with the provisions of Section 10 of the Act. The CPIO shall also indicate, wherever redaction has been carried out, the grounds under which such exemption is claimed, along with a justification for the same. The said directions shall be complied with within 15 days of receipt of this order, under intimation to the Commission.

8. In view of the above observations and directions, the appeals are disposed of accordingly.

Copy of the decision be provided free of cost to the parties.

Sd/-

(Anandi Ramalingam) (आनंदी रामिलंगम) Information Commissioner (सूचना आयु ) िदनांक/Date: 13.06.2025 Authenticated true copy O. P. Pokhriyal (ओ.पी. पोख रयाल) Dy. Registrar (उप पंजीयक) 011-26180514 Page 8 of 9 Addresses of the parties:

1. The CPIO, Himachal Pradesh Gramin Bank, Recovery & NPA Section, Head Office, Jail Road, Panjethi, Mandi, Himachal Pradesh - 175001
2. Natraj Ramaswamiah Gubbi Page 9 of 9 Recomendation(s) to PA under section 25(5) of the RTI Act, 2005:-
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