COMMENTS / OBJECTIONS / SUGGESTIONS : ref:PN/DoPT/OM/2010/RTI/AAA-0000-010

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:  21-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-0000-010
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

I OBJECT to the following rule proposed.

"3. Appointment of Secretary to the Commission: The Government shall appoint an officer not below the rank of Additional Secretary to the Government of India as Secretary to the Commission who shall be the Chief Executive Officer and Registrar General of the Commission."

I say this for the following REASONS

1) Because, there RTI Act does not PROVIDE for posts of "Chief Executive Officer" or "Registrar General" and this is objectionable.

2) Because I have no objection to a Secretary being appointed for the Commission, and I welcome and strongly endorse that the Government desires to appoint an officer of Addl.Secretary or above rank to the post of Secretary.

If these posts are required by any other law, then I SUGGEST that Act be amended to reflect this. If not I SUGGEST that all the posts be deleted.

I also Suggest that this rule be thoroughly tested on the anvil of section 13(6) of the RTI Act which deals with employees and other officers to be provided to the Commission and the limited scope of matters which may be prescribed for this.

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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