Dear all,
To add my two bits to the discussion:
Even when Management regulations are notified in the Gazette they will not
be law. To become law they should have been approved by Parliament. However
I do not agree that the CIC cannot make these regulations for itself. This
enabling provision is sorely missing from the main Act no doubt. However the
appeals rules do not contain much detailing of procedure. The Manual of
Office Procedure of the Central Sectt. may be used but it will have limited
value as the CIC's work is more specialised than a routine government
office.
The CIC has to function even in the absence of detailed rules. Unless the
DoPT comes out with very detailed appeals rules  nothing bars the CIC from
having regulations of its own, so long as it does not overstep the main Act.
The CIC Regulations do create unnecessary encumbrances for appellants and
complainants. I had drafted a critique for CHRI, the organisation I work
with, soon after the regulations were passed and sent it to the CIC. CIC
promised that it would not implement it word for word as there was a lot of
resistance from CSOs at that point of time. However with time the
regulations have come to be accepted by many appellants. The CIC is also
following it largely. but they took out one progressive regulation which
allowed for review of a decision based on a claim of error of law or of
facts. I have taken the benefit of this regulation for an acquaintance and
know that it is useful. However the CIC in its own wisdom chose to delete
it. So these days the only way we can challenge some of the decisions that
are not in tune with what we think is the letter and spirit of the RTI Act
is through a writ petition in the High Court. In addition to CIC the SICs of
Uttarakhand and Andhra Pradesh have also brought in their regulations.
As there is a lot of controversy regards the regulations we have not
uploaded them on the CHRI website for which I have received some criticism
from an RTI watcher also. Nevertheless once the validity of the regulations
is upheld in some formal manner, we will upload them on our website as well.
Thanks
Venkat 

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf
Of Vishnu Mutthu
Sent: Wednesday, August 05, 2009 3:38 PM
To: [email protected]
Subject: [rti_india] Re: ACTIVE DEBATE #1 (CIC Management Regulations, 2007)

Dear Mr Sarbajit

This is a very good step you have taken. Good discussion is badly needed in
the group.

I am also FOR the motion - the Regulations are absolutely illegal.

1) After reading section 12 of RTI Act i find
a) the Central Information Commission ("Commission") is a BODY and not any
individual like Mr Habibullah. Therefore all the decisions of CIC must be
"collective" decisions. Yet, in many cases, we find that orders of one I.C.
are contradicting another I.C.

b) the  "general" supervision / direction / management of the Commission to
"vest in" the Chief Information Commission. This actually reaffirms that the
CIC is a collective body and that the Chief Information Commissioner is not
SPECIFICALLY responsible for any decision / action / omission of the
Commission.

c) the limitation of 12(4) viz,  " may exercise all such powers and do all
such acts and things which may be exercised or done by the Central
Information Commission autonomously without being subjected to directions by
any other authority under this Act." is placed on the Commission as a whole
and not on the Chief Information Commissioner.
It is clear that the Commission can only exercise powers and do things which
cannot be done by any other authority under the Act. So the Commission has
no rule making powers since these are with the "government". In Indian law
there is no distinction between "Law", "Rule" and "Regulation". In fact till
1833 India's "laws" were known as "Regulations". WHERE IS THE CONSENSUS OF
THE BODY OF CIC TO FRAME THESE REGULATIONS? (This is clearly a individual
ill-advised action of Mr Habibullah and his cronies).

2) If the Management Regulations are "notified" then there will be a Gazette
Notification. So far there is no Gazette Notification. Not only has the DoPT
has refused to notify these Regulations but DoPT has also challenged the
legal basis or power of 12(4) for CIC to frame these regulations. WHERE IS
THE GAZETTE NOTIFICATION? WHERE IS THE OFFICIAL HINDI TRANSLATION OF THESE
REGULATIONS? (I have asked Indian Embassy at Paris but they do not have it)

3) I also find that CIC has tampered with crucial definition of
"prescribed".
In RTI Act ""prescribed" means prescribed by rules made under this Act by
the appropriate Government or the competent authority, as the case may be;"
In CIC Regulations ""Prescribed" means prescribed by or under the Act or
under the Rules or Regulations."
WHEN THE PARENT ACT DOES NOT PERMIT PRESCRIPTION TO BE ANY OTHER WAY BUT BY
RULES, HOW CAN MR. HABIBULLAH NOTIFY SUCH REGULATIONS?

Yours
Dr Vishnu Mutthu

--- In [email protected], "sroy1947" <sroy1...@...> wrote:
>
> Topic:
>
> "This House believes that the 'CIC Management Regulations, 2007' have no
basis/force in law, and 'inter alia' contravene/dilute the parent "RTI Act
2005" and the duly notified Rules published by Central Government thereunder
to the detriment of citizens"
>
> Proposed by
> Sarbajit Roy
> "FOR" the motion
>
> Kindly identify yourself as "FOR" or "AGAINST" the motion while setting
out your case.
>
> If there is insufficient representation for any "side", the Moderators
shall "honour" 1 or 2 "Devils advocates".
>
> If there is insufficient participation in this and other future debates -
the Moderators shall dissolve this group.
>
> Reference Material:
> http://cic.gov.in/CIC%20Regulations,%202007.pdf
> http://cic.gov.in/rti-act.htm
> http://cic.gov.in/CIC-Notifications/CIC%20Appeal%20Rules.pdf
>


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