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Who is watching the watchdog? Gujarat’s proactive disclosure mandate in shambles

 
By Jag Jivan 
A stunning failure in transparency has been uncovered in Gujarat, where only 75 out of 11,883 public authorities have submitted mandatory compliance certificates for proactive disclosure under the Right to Information (RTI) Act, 2005. This revelation comes from an analysis of an official government press note and related RTI correspondence obtained by a citizen. 
According to a press note dated April 22, 2026, the General Administration Department (GAD) had issued a circular on July 17, 2019, mandating that all public authorities prepare and update 17 points of Proactive Disclosure (PAD) under Section 4 of the RTI Act
Heads of departments, collectors, and corporations were required to complete an inspection-cum-audit of their PADs and submit certificates by June 30 each year. However, an RTI application filed by Alpeshkumar Bhavsar (Application No. 20251002216962) and the subsequent first and second appeals have exposed a systemic collapse.
As per the press note, of the state’s total 11,883 public authorities, only 75 have submitted the required PAD compliance certificates. The department responsible for monitoring this entire process—the General Administration Department (GAD)—has reportedly not submitted its own PAD certificate. 
Among the few departments that did submit certificates, the situation remains grim. Ten departments have information on their websites that is one to two years old, four departments have non-functional links for their PADs, and the Urban Development and Urban Housing Department has PADs as old as 15 years, dating back to 2012.
The RTI process revealed a complete abdication of responsibility. The Public Information Officer (PIO) and First Appellate Authority (FAA) of the GAD stated that monitoring PAD compliance is not the responsibility of the GAD or its RTI Cell. Even before the Gujarat State Information Commission, the GAD claimed it only had data for the 16 departments under its direct purview, with no information on the remaining 11 departments. 
The press note highlights that this disregard for PAD updating continues despite a Supreme Court order in Writ Petition (Civil) No. 990 of 2021 directing the State Information Commission to ensure proper implementation of Section 4 of the RTI Act.
Bhavsar’s RTI journey was arduous. The PIO initially refused to provide consolidated information, asking him to file separate RTIs with each of the over 11,000 public authorities. This decision was upheld by the First Appellate Authority. In his second appeal before the State Information Commission (Appeal No. A-0359-2026), the State Information Commissioner, Manoj Patel, passed an order dated April 10, 2026, holding that the PIO’s response was “proper” and dismissing the appeal. 
However, during the hearing, the PIO agreed to provide the applicant with a copy of the audit certificate for the Gujarat Information Commission, the only public authority under the RTI Cell’s direct control, and a list of departments that had submitted Annexure-B certificates. The order also noted suggestions from the appellant to make the RTI portal more user-friendly, which the Commission recommended to the Science and Technology Department.
The documents paint a clear picture: despite Supreme Court directives, government circulars spanning over a decade from 2009 onwards, and the existence of an Information Commission, the proactive disclosure mandate of the RTI Act, which is the very heart of transparency, has been systematically ignored. Citizens are effectively forced to file separate RTIs with each of the 11,883 public authorities to access information that should be voluntarily available online, rendering the spirit of the law virtually meaningless in Gujarat.

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