Monday, December 20, 2010

COMMENTS / OBJECTIONS / SUGGESTIONS : ref:PN/DoPT/OM/2010/RTI/AAA-0000-001

To:
The Government of India, by
Shri R.K.Girdhar
Under-Secretary/RTI
Department of Personnel and Training, North Block
New Delhi 110011

1) CONFIDENTIAL,
2) SECRET,
3) My Intellectual property,
4) Not to be disclosed to any unauthorised person,
5) Not to be disclosed to any private person whatsoever,
6) Not to be disclosed to Prime Minister or his office,
7) Not to be disclosed to National Advisory Council,
8) Not to be disclosed under Right to Information except to myself,

BY EMAIL:


Date:  20-December-2010
Your Ref: OM dated 10.12.2010 in File No.1/35/2008-IR (draft RTI Rules)
Our Ref:  PN/DoPT/OM/2010/RTI/AAA-0000-001
Subject
Objections and/or Suggestions to the amendments proposed

Sir,

I refer to the above citations and your subject OM. I am caused to submit the following objection(s) and/or suggestion(s) to the same.
This is separate, distinct and without prejudice to other objections I may submit from time to time within the period allowed..

1) I observe that by this OM you require "comments" to be filed by email.

2) I OBJECT to  be compelled to submit my comments, including my objections and/or suggestions by email. I insist that I (or any other interested person, including my group members)  be given the opportunity to submit our representations in writing ie. hard copy by registered post..

3) I am objecting thus for the following REASON(S) / DEFECT(S):

a) Because Email is not a secure form of communication

b) Because no proof of receipt is provided to objectors.
c) Because, in law, only person who posses electronic signature can submit their comments by email to this draft amendments.

d) Because equity requires that State cannot compel anyone to file documents only in electronic form. I shall rely upon section 9 of the Information Technology Act to buttress this submission.

e) Because the State cannot presume or verify that the identity of the person filing the comments are authentic. (I apprehend that some NGOs are creating numerous fake email IDs to make representations on these amendments).

f) Because the impugned OM does not specify that persons filing their comments should sign it, or verify it, or provide their name and/or address and/.or other contact particulars.

4) Accordingly, I am constrained to SUGGEST / REQUIRE that the OM or any other means of accepting response from the public, be amended to remove all the defects which I have listed above.

Submitted in my individual capacity by


Er. Sarbajit Roy
B-59 Defence Colony
New Delhi 110024
Tel : 09311448069
email ID: "sroy.mb@gmail.com"

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