COMMENTS / OBJECTIONS / SUGGESTIONS : ref:PN/DoPT/OM/2010/RTI/AAA-0000-002

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-0000-002
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..

http://persmin.gov.in/WriteReadData/RTI/RTI_rules_01122010-1.pdf

1) That I am only submitting this communication upon being informed by the office of Jt.Secy/DoPT Shri Rajiv Kapoor that members of the public can also submit their objections / suggestions / comments on the draft Rules published vide the referred OM on website of Personnel Ministry. I spoke to JS/DoPT's office only after reading reports in reputed newspapers that the Govt had invited comments from the public on these Rules.

2) In this context I wish to OBJECT that device of Office Memorandum cannot be utilized to invite comments / objections / suggestions from the public at large. I shall rely upon the definition of "Office Memorandum" as published by your Department in the Manual of Office Procedure.

3) I further OBJECT that this highly irregular practice of using Office Memorandum (instead of a formal and statutory Public Notice) to disclose draft Rules and seek comments has been corruptly done at behest of Shri Rajiv Kapoor so as to facilitate a network of non-Govt employees, former IAS officers, touts and Maoists etc. who are ensconced within an extra-statutory body which I describe and specify as "National Advisory Council" to gain access to privileged and confidential drafts of Govt. and interfere with government process.

4) I SUGGEST and REQUIRE that all the officers of Government who are implicated in the usage of this unlawful procedure be prosecuted under departmental vigilance rules and/or the Official Secrets Act and/or Prevention of Corruption Act etc., and that all members of the public (except me) who cite or quote any portion of these draft rules to which they are not authorised to have access be likewise prosecuted under the Official Secrets Act read with the Indian Penal Code.

5) I further SUGGEST that a formal Public Notice be issued and widely publicised so that the views of all (ie. as many as possible)  stakeholders in RTI process may be garnered and considered, and has been assured by Prime Minster to Chairperson UPA..

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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