The case of Yogi M P Singh vs. ROC Mumbai highlights several critical lessons for RTI activists and citizens seeking government accountability.

Here are the key takeaways from the dispute:

1. The “Website Referral” Trap

A common tactic used by CPIOs is to provide a generic URL (like mca.gov.in) rather than specific data. As seen in this case, the CPIO avoided direct answers by claiming the information was already in the public domain. This shift in burden—from the officer providing data to the citizen searching for it—is a major hurdle in modern RTI practice.

2. The Duty of Specificity

The appellant’s core argument provides a brilliant blueprint for others: If information is online, the CPIO must provide direct, functional links. Simply pointing to a homepage is insufficient if the specific “information points” are not easily accessible through a standard search.

3. The Limitation of the First Appeal

This case demonstrates that the First Appellate Authority (FAA) often resides within the same department and may be hesitant to overturn a colleague’s decision. Mr. Cholarajan’s refusal to interfere despite the appellant’s valid claim that the information was “not found” on the site shows that the FAA stage is often just a procedural stepping stone toward the Central Information Commission (CIC).

4. Essential RTI Timeline & Hierarchy

Understanding the progression of an RTI dispute is vital for success. The sequence in this case followed a standard but frustrating path:

• Initial Request: Denied/Vague reply provided.
• First Appeal: Filed when the CPIO’s reply is unsatisfactory.
• FAA Disposal: Often upholds the CPIO’s view.
• Second Appeal: The final legal recourse at the Central Information Commission (CIC).

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5. Actionable Strategy for Applicants

If you receive a reply directing you to a website:

• Document the Search: Take screenshots showing that the specific information is missing or the link is broken.
• Invoke Section 4: Remind the authority that under Section 4, they have a “proactive disclosure” requirement to make data easily accessible.
• Demand Direct URLs: Explicitly ask for the exact path to the document in your appeal.

Transparency Denied: When “Search the Website” Becomes a Barrier to Information

The Right to Information (RTI) Act of 2005 was envisioned as a tool to empower citizens, ensuring that the government remains accountable and transparent. However, a growing trend among Public Information Officers (CPIOs) is to provide “evasive replies” by simply directing applicants to massive, complex government portals without specific guidance.

The case of Yogi M P Singh vs. The Registrar of Companies (ROC), Mumbai (Appeal No: ROCMU/A/E/25/00007) serves as a perfect case study for this systemic issue. It highlights the frustration of a citizen caught between a vague CPIO response and a First Appellate Authority (FAA) that refused to intervene.

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The Genesis of the Dispute: Request ROCMU/R/E/25/00026

The journey began on February 2, 2025, when the appellant, Mr. Singh, filed an RTI application seeking specific information from the Registrar of Companies, Mumbai. While the exact details of the query involved corporate compliance or officer data, the CPIO’s response on March 3, 2025, was a generic redirection:

“The applicant can visit MCA website http://www.mca.gov.in for the Companies Act, employees list, officers of the MCA, circular, notification, citizen charter etc.”

To a layperson, this might seem helpful. To an RTI activist or a concerned citizen seeking a specific needle in the digital haystack of the Ministry of Corporate Affairs (MCA), it is often a dead end.

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The Core Conflict: Public Domain vs. Accessibility

The central argument of the appeal rests on a critical distinction in the RTI Act: Information in the public domain must be accessible, not just existent.

Mr. Singh’s grievance was simple and logical. He followed the CPIO’s instructions and searched the MCA website. However, he found that the specific information he sought was either buried under layers of technical navigation or simply not present in the format requested.

The Appellant’s Prayer

Mr. Singh argued that if a CPIO claims information is available online, it is their duty to provide hyper-specific links. He requested that the First Appellate Authority direct the CPIO to:

1. Identify the exact location of the data.
2. Provide direct URLs that lead to the information points.
3. Ensure that the “search” does not result in a “404 Error” or a generic home page.

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The Role of the First Appellate Authority (FAA)

On April 7, 2025, the First Appellate Authority, Mr. N Cholarajan, issued his decision. The order was brief and, for the appellant, disappointing. The FAA noted that since the CPIO had provided a reply, and the information was supposedly on the website, the reply was “satisfactory.”

By stating there was “no interference” required, the FAA effectively endorsed the practice of “referral-based replies.” This highlights a significant bottleneck in the RTI hierarchy: when the First Appellate Authority acts as a rubber stamp for the CPIO, the burden of seeking justice shifts entirely to the Central Information Commission (CIC) in New Delhi.

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Why “Go To Website” is Often a Violation of the RTI Act

Legal precedents set by various Information Commissions suggest that a CPIO cannot simply point to a website if the information is not easily searchable. There are three main reasons why this practice is problematic:

1. The Digital Divide

Not every citizen is an expert in navigating complex government databases. The MCA portal, while comprehensive, requires a level of technical literacy to filter through thousands of companies and filings.

2. Section 4 Compliance

Under Section 4 of the RTI Act, public authorities are required to proactively disclose information in a manner that is easily accessible to the public. If a citizen has to file an RTI just to find something that should be “proactively disclosed,” the system has already failed.

3. Specificity of Information

If an applicant asks for “Point A,” and the CPIO points to a library containing “Points A through Z,” the CPIO has not fulfilled their duty. The law requires the provision of the information, not the location of a building where the information might be kept.

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Next Steps for the Appellant: The Second Appeal

The FAA’s order explicitly grants the appellant the liberty to prefer a Second Appeal before the Hon’ble Central Information Commission (CIC) in New Delhi.

Detail	Information for Second Appeal
Location	Room No. 305, 2nd Floor, B Wing, August Kranti Bhavan
Address	Bhikaji Cama Place, New Delhi
Key Argument	Non-compliance with the spirit of “access” to information

For Mr. Singh, the road to transparency now leads to the national capital. His case stands as a reminder that the “Right to Information” is not just the right to be told where to look—it is the right to see the data itself.

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Conclusion: A Call for Specificity

The case of ROCMU/A/E/25/00007 is a microcosm of a larger struggle for administrative accountability. When public authorities hide behind URLs, they dilute the power of the RTI Act. Transparency is not a scavenger hunt; it is a fundamental right.

Moving forward, it is essential for the CIC to set stricter guidelines: if a CPIO refers to a website, they must provide the direct link. Anything less is a denial of information in disguise.

To help you move forward with your legal or administrative follow-up, here is the structured contact directory for the concerned public authorities involved in the RTI appeal (ROCMU/A/E/25/00007).

1. Primary Public Authority (ROC Mumbai)

Authority	Registrar of Companies (ROC) Maharashtra, Mumbai
Address	100, Everest Building, Marine Drive, Mumbai – 400002
Official Website	www.mca.gov.in
General Email	roc.mumbai@mca.gov.in
Main Office Line	022-22812627 / 022-22846954

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2. Key RTI Officers Involved

These are the specific officials who handled your original application and the subsequent first appeal.

• Nodal Officer / CPIO (Central Public Information Officer):
  • Name: Pranav Agja (Assistant Registrar of Companies)
  • Email: pranav.agja@nic.in (or pranav.agja@mca.gov.in)
  • Telephone: 022-22812645
• First Appellate Authority (FAA):
  • Name: N. Cholarajan (Deputy Registrar of Companies)
  • Email: cholarajan.natarajan@mca.gov.in
  • Telephone: 022-22812645

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3. Regional Oversight (For Further Escalation)

If you find the response from the Mumbai ROC insufficient, the next administrative level is the Regional Director.

• Regional Director (Western Region):
  • Name: Sh. Santosh Kumar (or the current incumbent)
  • Address: Everest 5th Floor, 100 Marine Drive, Mumbai-400002
  • Email: rd.west@mca.gov.in
  • Phone: 022-22817259 / 022-22811493

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4. Direct Information Links (Point-wise Redressal)

Based on the CPIO’s claim that information is on the website, you can use these direct paths to verify if the information exists:

• Employee/Officer Directory: MCA Officials Search
• Citizen Charter: MCA Citizen Charter Page
• RTI Disclosures (Section 4): Proactive Disclosures under RTI

Important Note: When filing your Second Appeal to the Central Information Commission (CIC), you must include your Request Registration Number (ROCMU/R/E/25/00026) and the Appeal Registration Number (ROCMU/A/E/25/00007) as the primary identifiers.

Would you like me to draft a formal letter to the Regional Director (Western Region) asking for an administrative review of the FAA’s decision?