Supply of requested RTI information fulfilled the Act’s primary purpose, warranting dismissal of the writ petition.

The petitioner applied under the Right to Information Act, 2005, on 12 November 2013 for a copy of FIR No. 513/2013. After the information was not provided, he filed a first appeal, which was dismissed, and then a second appeal.

The information was supplied on 20 June 2021, shortly before the Second Appellate Authority disposed of the appeal on 21 June 2021. Although that authority noted the delay and the subordinate authority’s misunderstanding of the statutory provisions, it did not impose a penalty under Section 20 of the RTI Act. The petitioner sought compensation of ₹25,000 from the High Court.

1. Whether the High Court should direct payment of ₹25,000 compensation for the delayed provision of information under the RTI Act

2. Whether further proceedings before the High Court were warranted after the requested FIR had been supplied

Section 20 of the RTI Act was invoked by the petitioner as the basis for seeking a statutory penalty against the responsible officer.

The judgment did not set out or apply a substantive test under Section 20, nor did it determine whether a penalty or compensation was legally warranted. It noted that the information had been supplied and referred to the High Court’s jurisdiction under Article 226 of the Constitution.

The Court treated the petitioner’s receipt of the FIR as fulfilment of the primary purpose of the RTI request. On that basis, it concluded that no further proceedings before it under Article 226 were required.

It did not separately examine the recorded delay, the alleged failure to impose a Section 20 penalty, or the claim for compensation.

No compensation or other relief was granted.