Central Information Commission
Radhey Lal Gupta vs Punjab National Bank on 8 December, 2025
के न्द्रीय सूचना आयोग
Central Information Commission
बाबा गंगनाथ मागग,मुननरका
Baba Gangnath Marg, Munirka
नई दिल्ली, New Delhi - 110067
नितीय अपील संख्या / Second Appeal No. CIC/PNBNK/A/2024/653339
Radhey Lal Gupta ... अपीलकताग/Appellant
VERSUS
बनाम
CPIO:
Punjab National Bank,
Bulandshahar, Uttar Pradesh ...प्रनतवािीगण/Respondent
Relevant dates emerging from the appeal:
RTI : 11.08.2024 FA : 09.10.2024 SA : Nil
CPIO : 10.09.2024 FAO : 30.10.2024 Hearing : 27.11.2025
Date of Decision: 08.12.2025
CORAM:
Hon'ble Commissioner
_ANANDI RAMALINGAM
ORDER
1. The Appellant filed an RTI application dated 11.08.2024 seeking information as under:
"I previously filed an RTI application on 9 August 2024, seeking all relevant documents pertaining to this loan. While I acknowledge the receipt of a response, the information provided was incomplete. Specifically, the sanction and renewal letters were either absent or lacked crucial details. The incomplete documents included:
1. A letter dated 24 August 2024, which communicated terms and conditions of the loan to the borrower without specifying the actual terms.Page 1 of 6
2. Terms and conditions of the loan sanction dated 13 November 2024, devoid of borrower and guarantor acknowledgements.
To ensure a comprehensive understanding of the loan agreement, I request the following:
1) Complete copies of all sanction and renewal letters issued for Lord Shiva Associates.
2) Detailed terms and conditions associated with each sanction and renewal.
3) Acknowledgement copies from both the borrower and guarantor for all loan sanctions."
2. The CPIO replied vide letter dated 10.09.2024 and the same is reproduced as under:-
"This has reference to your aforesaid application under Right to Information Act, 2005. This is to inform you that Guarantee Agreement is executed at the time of loan sanction. In guarantee agreement it is mentioned "the Guarantor(s) agree(s) and declare(s) that he/she/they shall remain liable to the Bank for any indebtedness of the Borrower under the renewed facilities / limits and the terms and conditions of this Agreement shall apply and govern his/her/their liability under the renewed facilities / limits". At the time of renewal of accounts. no document is signed by the Guarantor hence renewal letters cannot be provided. If you have any queries, then kindly raise a complaint on the bank's complaint portal."
3. Dissatisfied with the response received from the CPIO, the Appellant filed a First Appeal dated 09.10.2024. The FAA vide order dated 30.10.2024 attached the documents related to account M/s Lord Shiva Associates.
4. Aggrieved with the FAA's order, the Appellant approached the Commission with the instant Second Appeal dated Nil.
Page 2 of 65. The Appellant was represented by Himanshu Jalan during the hearing and on behalf of the Respondent, Lisha Srinivasan, CM & Rep. of CPIO attended the hearing through BharatVC.
6. The Rep. of the Appellant referred to the written arguments filed by the Appellant on 19.11.2025 wherein it was stated as under:
"3. Grounds for Second Appeal 3.1. Information squarely falls under Section 2(f):
Sanction and renewal letters are official records created by the Bank and routinely issued to borrowers and guarantors. They are not internal notes or deliberations.
3.2. No valid exemption invoked:
Neither the CPIO nor the FAA has cited any statutory exemption. The justification offered ("not signed by guarantor") is not a ground for denial under the Act.
3.3. Section 8(1)(d) is inapplicable:
Sanction letters do not contain trade secrets or commercial confidence. Banks routinely share sanction terms with guarantors. Even otherwise, as an alleged guarantor, I am entitled to the information to understand my liability. The Bank cannot enforce liability on me while simultaneously concealing the documents that determine that liability.
3.4. Violation of Bank's Internal Guidelines:
The refusal to provide the sanction letters is contrary to Bank's own internal guideline (Annexure-E, Page 2) which mandates:
"A letter is sent to the borrower/guarantor along with annexure containing the details of the facilities sanctioned and the respective terms and conditions."
3.5. Partial and Misleading Information:
Page 3 of 6Providing only the 2018 sanction letter and withholding the renewal letters amounts to misleading and partial disclosure, attracting Section 20(1).
4. Pattern of Concealment and Evasive Responses 4.1. Multiple Attempts Since February 2024:
Since February 2024, I have made more than 20 written attempts-letters, emails, complaints, and multiple RTIs to obtain these records (chronology enclosed as Annexure- F).
4.2. Shifting Grounds for Denial:
The Bank has repeatedly shifted its justification for denying sanction/renewal letters clearly showing intention to evade disclosure:
In this RTI: "Not signed by guarantor."
RTI No. PNBNK/R/E/25/01481 (01-06-2025): "Not information under Section 2(f)." Appeal PNBNK/A/E/25/00355 (13-06-2025): "Exempt under Section 8(1)(d) 4.3. Incorrect/Irrelevant Information Provided:
After intervention by the RBI Ombudsman, the Bank provided one renewal letter. However, upon escalation for the remaining letters, the Bank attempted to pass off internal renewal proposals/appraisal memos as sanction letters.
4.4. Motive for Concealment:
The Bank is withholding these letters to conceal substitution of the principal borrower to a different legal entity which directly impacts the validity of my alleged guarantee."
7. The Respondent reiterated the replies on record and submitted that the available and permissible information has been provided to the Appellant.
8. The Commission after adverting to the facts and circumstances of the case, hearing both parties and perusal of records, observes that there is lack of clarity in the Appellant's Page 4 of 6 insistence for information to be provided as he harps on "all" sanction letters while holding the view that -'the Bank attempted to pass off internal renewal proposals/appraisal memos as sanction letters.' The factual matrix of the instant case suggests a continuing grievance of the Appellant against the Respondent being pursued through the channel of RTI Act under garb of seeking information. Here, the Appellant is advised about the powers of the Commission under the RTI Act by relying on certain precedents of the superior Courts as under:
The Hon'ble High Court of Delhi in the matter of Hansi Rawat and Anr. v. Punjab National Bank and Ors. (LPA No.785/2012) dated 11.01.2013 has held as under:
"6. ....proceedings under the RTI Act cannot be converted into proceedings for adjudication of disputes as to the correctness of the information furnished."
The aforesaid rationale finds resonance in another judgment of the Hon'ble Delhi High Court in the matter of Govt. of NCT of Delhi vs. Rajender Prasad (W.P.[C] 10676/2016) dated 30.11.2017 wherein it was held as under:
"6. The CIC has been constituted under Section 12 of the Act and the powers of CIC are delineated under the Act. The CIC being a statutory body has to act strictly within the confines of the Act and is neither required to nor has the jurisdiction to examine any other controversy or disputes."
While, the Apex Court in the matter of Union of India vs Namit Sharma (Review Petition [C] No.2309 of 2012) dated 03.09.2013 observed as under:
"20. ...While deciding whether a citizen should or should not get a particular information "which is held by or under the control of any public authority", the Information Commission does not decide a dispute between two or more parties concerning their legal rights other than their right to get information in possession of a public authority...." (Emphasis Supplied) Page 5 of 6
9. Having observed as above, no relief is warranted in the matter. The Appellant is advised to pursue his grievance before the appropriate forum.
10. The Appeal is dismissed accordingly.
Copy of the decision be provided free of cost to the parties.
Sd/-
(Anandi Ramalingam) (आनंिी रामललंगम) Information Commissioner (सूचना आयुक्त) दिनांक/Date: 08.12.2025 Authenticated true copy O. P. Pokhriyal (ओ.पी. पोखररयाल) Dy. Registrar (उप पंजीयक) 011-26180514 Addresses of the parties:
1. The CPIO, Punjab National Bank, Circle Office, IAD, Near RTO Office, Yamuna Puram, Bulandshahar, Uttar Pradesh - 203001
2. Radhey Lal Gupta Page 6 of 6 Recomendation(s) to PA under section 25(5) of the RTI Act, 2005:-
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