CIC Urges Responsible RTI Use Amidst Chronic Complaints Challenge

CIC Flags Misuse of RTI in SEBI Complaint Case: A Reminder on the Limits of Transparency Tools

In a rare but instructive development, the Central Information Commission (CIC) has weighed in on the repeated use—and eventual misuse—of the Right to Information (RTI) Act by an individual complainant, Geeta Khattar, in her extended correspondence with the Securities and Exchange Board of India (SEBI).

While the RTI Act remains a cornerstone of public transparency in India, this case raises important questions about the line between civic accountability and procedural overload, particularly in the age of digital grievance redress.

At the Centre: A Torrent of Repetitive RTI Requests

Between April 1, 2021 and late 2024, Geeta Khattar filed 578 RTI applications and appeals, primarily aimed at SEBI. Most revolved around similar grievances—procedural dissatisfaction, complaint-handling concerns, and allegations of misconduct—despite earlier responses and redress opportunities.

According to both SEBI and CIC records, the filings were largely repetitive, often overlapped in substance, and offered little that was materially new.

SEBI’s Response: Labeling as a “Chronic Complainant”

Faced with the volume and duplication of Khattar’s filings, SEBI invoked a lesser-known provision outlined in its SCORES (SEBI Complaints Redress System) FAQ, specifically Questions 31 and 32, which allow the regulator to designate an individual as a “chronic complainant” under specific circumstances.

The conditions met in this case included:

• Repeatedly filing unsubstantiated complaints
• Rejecting SEBI’s closure reports or other redress options
• Non-appearance at hearings or failure to clarify claims
• Absence of engagement in meaningful correspondence

As a result, SEBI suspended Khattar’s access to the SCORES platform, including the disabling of her registered email ID for complaint submissions. The decision was taken as a measure to preserve the functionality of the system and safeguard institutional resources.

What SEBI Said: Strains on Regulatory Capacity

In its communication dated December 9, 2022, SEBI’s First Appellate Authority, Ruchi Chojer, stated:

“The repeated RTI filings add significant strain to our regulatory and public information handling teams. They impact our ability to respond fruitfully to genuine public interest queries.”

SEBI also noted that the nature of the filings diverted limited regulatory resources away from more constructive public interactions.

CIC’s Final Word: A Call for Sincerity in RTI Use

The CIC adopted a measured tone in its advisory, reaffirming the foundational importance of the RTI Act, but also cautioning against its misuse.

“The multiplicity of frivolous RTI applications significantly burdens the operations of public authorities. Applicants are requested to use this valuable constitutional tool sincerely and responsibly.”

Notably, the CIC cited Khattar’s consistent non-appearance at hearings, her failure to respond to postal and digital notices, and the lack of specificity in her RTI filings as grounds for supporting SEBI’s classification.

What It Means to Be a "Chronic Complainant"

Under SEBI’s SCORES protocol, individuals designated as chronic complainants may:

• Have their SCORES access blocked

• Lose email privileges for filing future grievances

• Be required to submit a written undertaking promising to:

  • Avoid repetitive or baseless filings
  • Use alternate remedies where applicable
  • Cooperate with procedural norms

SEBI may restore access if it is satisfied with the intent and nature of the undertaking.

The Broader Framework: RTI and SCORES at a Glance

Platform	Primary Purpose	Access Conditions
RTI (via SEBI’s CPIO)	General information and regulatory disclosure requests	Open to all Indian citizens
SCORES	Complaint redress system for investor grievances against SEBI-regulated entities	Requires registration, classification, and documentation

SEBI is among the most active public institutions in terms of RTI volume, reflecting a healthy appetite for transparency—but also the need for efficient complaint management.

The Balance Between Rights and Responsibility

The Khattar case is not a condemnation of the RTI Act—far from it. Both SEBI and the CIC acknowledged its essential role in deepening democratic accountability.

But the case does underline a crucial boundary: rights must be paired with reasonable civic conduct. When a regulatory institution receives hundreds of nearly identical queries from the same individual, particularly in the face of non-cooperation and refusal to pursue alternate remedies, it risks turning transparency into a bottleneck.

For digital grievance platforms like SCORES to remain credible, the system must be protected from being overwhelmed by volume, repetition, or procedural intransigence.

Conclusion: The Integrity of Participation

The case of Geeta Khattar vs SEBI offers a timely reminder for activists, investors, and citizens: democratic tools like RTI are powerful—but not infinite. Their legitimacy depends not just on access, but on how they are used.

In the end, both regulators and petitioners share responsibility:

• SEBI must ensure it remains open, fair, and accountable in its complaint redress.
• Petitioners must respect the integrity of processes designed to serve the broader public interest.