The Power of Information: Exploring the Evolution and Impact of RTI Laws

Paper Details 

Paper Code: RP-VBCL-10-2025

Category: Research Paper

Date of Publication: April 20, 2025

Citation: Mrs. R.K. Varrsha & Mr. M.Surendar, “The Power of Information: Exploring the Evolution and Impact of RTI Laws", 2, AIJVBCL, 139, 139-152 (2025).

Author Details: Mrs. R.K. Varrsha, Asst. Prof of Law, School of Law, Joy University, Tamilnadu

Mr. M. Surendar, Asst. Prof of Law, School of Law, Joy University, Tamilnadu

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ABSTRACT

The Right to Information (RTI) Act is an effective mechanism that promotes good governance and strengthens democracy by enhancing citizens' ability to participate in the decision-making process. To every individual Right to Information act is a fundamental human right. The famous French philosopher Michel Foucault once pronounced, power is derived from knowledge and information is the basic component of knowledge. Information not only makes men wise and it moulds the citizen to be competent enough to cope up with the contemporary world. Transparency and accountability in administration are crucial components without which (sine qua non) participatory democracy cannot be achieved. Information serves as the essential element for any citizen to thrive within the social framework of society and uphold its democratic equilibrium. The Right to Information (RTI) in India has emerged through judicial interpretations, thereby distinguishing itself as a Fundamental Right under Article 19(1). This paper examines the origins, principles, transformative effects, democratic transparency, and challenges associated with the implementation of the Right to Information (RTI) Act, as well as the role of awareness in increasing public participation, improving accountability, and cultivating an informed citizenry. Further through by examining case studies on the usage of RTI, the paper also reveals the scenario of how this legislation has empowered individuals to challenge administrative practices and demand greater transparency in public affairs. Ultimately, this paper contends, through case studies and doctrinal analysis, that RTI not only functions as an instrument for legal and administrative reforms but also fortifies democracy by narrowing the divide between the government and the governed, serving as a catalyst for cultivating a culture of informed citizenship and reinforcing the pillars of democratic governance.

Keywords: Right to Information, Participatory Democracy, Civic Engagement, Barrier in Implementation, Good governance, RTI Activist, Democratic Transparency.

INTRODUCTION

“A government which functions in secrecy not only acts against democratic decency but also buries itself with its own burial.”

-          Justice Krishna Iyer 

“Information is wealth” - Information is often regarded as wealth because it holds the power to create opportunities, drive innovation, and fuel growth. In the present era of knowledge-based economy, those who possess valuable information can make their own better decisions, gain competitive advantages of any subject matter, and unlock new avenues for success. Information is the cornerstone of a functioning democracy. It empowers citizens by enabling them to make informed decisions, hold governments accountable, and participate actively in civic life. Access to accurate and timely information fosters transparency, reduces corruption, and strengthens the relationship between the state and its people. In an era where knowledge is power, information serves as a critical tool for promoting justice, equity, and social progress.

The Law never fails to recognize right to receive information as an important tool, it was even envisaged in Article 19 of the Universal Declaration of Human Rights, established in 1948, affirms the right to freedom of opinion and expression, which includes the pursuit, acquisition, and dissemination of information, ultimately promoting transparency. However, the mechanisms for obtaining information from the government are not easily implemented. The architects of the Indian Constitution recognized the importance of the Right to Freedom of Speech and Expression within a democratic framework. The preamble emphasizes “liberty of thought,” and Article 19(1)(a) enshrines this as a fundamental right. The Supreme Court has endorsed the view that under a democratic set up, the people have right to know about the functioning of the Government[1]. Subsequently in another case[2], the Supreme Court held that the right to know news and information regarding administration of the Government is included in the freedom of press. Therefore, the Right to Information was declared as fundamental right, being an essential facet of Articles 19(1)(a) and Article 21[3].  There were many more such decisions that reiterated the fundamental right to know and access information. But still it has travelled a long way to get enact in India, before it reaches India. It has been implemented in many countries. The focus of this discussion, the Right to Information (RTI), is not a recent development. In reality, there exists a substantial historical context at the international level regarding the pursuit of this right and the mobilization of the public to secure it.

The earliest reference about the Act is found in Sweden where in 1766 the Freedom of the Press Act was passed it was largely motivated by the parliament’s interest in access to information held by the King.The Swedish example was later followed by the US, whichenacted its first law in 1966 and then by Norway in 1970. Similarly, several western democracies enacted their own laws (France and Netherlands 1978, Australia, New Zealand and Canada 1982, Denmark 1985, Greece 1986, Austria 1987, Italy 1990)[4].

The concept of the Right to Information began to develop in the 1970s, influenced by the judiciary's broad interpretation of several fundamental rights, particularly the right to freedom of speech and expression. In the landmark case of Bennett Coleman and Co versus the Union of India in 1973, the Supreme Court's majority opinion stated that the freedom of speech and expression encompasses the right of all citizens to access information and be informed[5].

By 1990, thirteen countries had passed Freedom of Information (FOI) legislation. The European Union Charter of Fundamental Rights, adopted in 2000, represented a significant step forward, as it encompassed both freedom of expression and access to documentation. By 2010, more than 85 nations have national-level RTI rules or regulations. So date, about 20 Asian countries has approved freedom of information laws.

In India, the current Act is the result of ongoing fight and efforts by numerous civil society organizations, NGOs, and social activists. The British also passed a statute prohibiting the dissemination of intelligence to hostile countries, known as the “official secrets act-1923”. The seed to seek information was first sowed in Rajasthan by the Members of Rajasthan's MazdoorKisanShektiSangathan (MKSS) an Association for the Empowerment of Labourers and Farmers; they first raised the demand in 1966 for government data and documentation, and what began as a simple demand for minimum wages evolved into a campaign for the Right to Information. They took the initiative to encourage people to request copies of bills, vouchers, and muster rolls. According to records, such projects were marked as completed although, in reality, the individuals had not received their compensation. The Rajasthan experience provoked demand for information in other States as well. The Chief Ministers Conference on “Effective and Responsive Government” held during 1997 also recognized the need for enacting a law on Right to Information.  The Government of India based on the recommendations of the Chief Ministersconference on “Responsiveness in Government,” appointed the Shourie Committee to suggest a draft RTI Bill. The draft, called the Freedom of Information Bill 2000 was passed into law in January 2003.But major restrictions in the Act became a hindrance to achieve the objective of transparency and accountability. Therefore the law was not notified and finally repealed.In the mean time several State Governments had already passed their own versions of RTI Acts. For example, in 1997 the RTI was passed in two states Tamilnadu and Goa.

In 2004, the United Progressive Alliance (UPA) government established the National Advisory Council (NAC). At that time, the Freedom of Information (FOI) Act was considered inadequate, lacking the constitutional recognition that the Right to Information (RTI) deserved. The NAC proposed several amendments to enhance the FOI Act. Subsequently, the central government opted to implement changes aimed at making the Act more inclusive and impactful. However, the government later chose to repeal the FOI Act and introduced the Right to Information Act, 2005, which established a robust framework for exercising the right to information as enshrined in Article 19 of the Indian Constitution. The RTI Act replaced the Freedom of Information Act of 2002 and abrogated the Official Secrets Act of 1923, along with various other laws from the British colonial era. This new legislation grants every citizen the right to access information held by public authorities. The Right to Information Act, 2005, received presidential assent on June 15, 2005. Certain provisions, such as the appointment of Public Information Officers and the establishment of Information Commissions, took effect immediately, while other sections were enacted on October 12, 2005. Since its implementation, social activists, civil society organizations, and ordinary citizens have effectively utilized the Act to combat corruption and promote transparency and accountability within the Government.

ROLE OF RTI IN DEMOCRATIC TRANSPARENCY

Democracy ensures that decision-making will be based on norms and procedures only there should not be any kind of discrimination or bias in nature. To ensure that democracy is really implemented without any negative implication every citizen has to be equipped with the right and means to examine the process of decision-making by which transparency is resorted. There are many Act in place to ensure the activity of the Government is democratic or not but it is only RTI which has a significant role to bring the information behind every democratic activity of the Government in the hands of citizen to ensure the Democratic Transparency.

RTI acts as a tool in bringing the concept of seek to information as a fundamental right. Thus main role of the RTI is to provide a direct line of communication between the Government and the people.The primary cause of the corruption escalation was a lack of systemic openness. Thus, the enactment of the right-to-information legislation has increased transparency in government operations and increased political accountability, thereby played a vital role in curbing the Corruption.By making government actions and decisions more transparent, RTI helps in curbing corruption and misuse of power. When public officials know that their actions can be scrutinized, they are more likely to act responsibly. It plays a role in analyzing the effects of good governance, accountability, and transparency in the nation through its provisions. The role of RTI is to boost citizen engagement to the democracy and to inspire to participate in governmental process. When people have access to information, they can engage more effectively in public debates and decision-making processes.Transparency fosters trust between the government and the public. When citizens see that their government is open and honest, they are more likely to have confidence in its actions and decisions. The significant role played by the RTI is that all the public administrators were forced work in a clandestine environment and in strict adherence to the law being in force, since openness goes against their training and way of thinking. Thus, the RTI legislation has played a significant role to India's governmental structure.The main shift brought about by RTI is that public officials now recognize that the Indian public may hold them responsible for their wrongdoings

THE FUNCTIONS OF CENTRAL AND STATE GOVERNMENTS

The functions of the Central/ State governments include interalia the following:

1.      Create educational initiatives on the RTI, with a focus on reaching marginalized communities.

2.      Motivate Public Authorities to take part in conducting these programmes.

3.      Provide training for officers and to prepare relevant training resources.

4.      Prepare and distribute a User Guide for the public in the local official language.

5.      Make available the names, titles, postal addresses, and contact information of PIOs and other relevant officials in the conspicuous place.

EMPOWERING CITIZENS THROUGH INFORMATION

The Right to Information (RTI) Act is a powerful tool that empowers citizens by granting them access to information held by public authorities. This access enhances transparency, accountability, and citizen participation in governance.By providing access to relevant information, the RTI Act empowers citizens to make informed decisions and participate meaningfully in the democratic process. For instance, citizens can use information obtained through RTI to question public policies, engage in public discourse, and influence decision-making processes.  Since all public authorities are accountable and liable for furnishing the information as required by the citizens this empowers them to move further against the corruption and to know whether such information is in adherence with rules.

RTI is incorporated with all most all state level Employment Exchange Board which empowers the citizen to know the real time instances of present job availability to the citizens as well as on what basis it has been allotted by seeking the information thorough RTI, to support and to not ignore the information by the citizens on lame reasons by any public authority RTI Act as many provisions through which it ensures the information can’t be ignored without a justification.

The Act was pinned in such a way that the approach to the information by the citizen should be easy and information should not be ignored as request was unable to made into writing as per Sec.6 the Act as clearly mentioned the request can be in writing, if the citizen was unable to write then the authority should make provisions for recording the request and also if it was unable to made in English then again Act empowers the citizens to file the request in their one language followed by the state, thus the RTI Act scope is to motivate every citizen to actively participate in knowing the accountability of the pubic authority and thereby empowering the citizens through information.

There have been cases when people as old as ninety years and as young as ten years have taken recourse to RTI to get their work done. The information that has received through the RTI as empowered them to resort and arrive into the solution for the improper function of the public authority. In the Koraput district, Orissa, the people Elengabalsa village of Bandhugaon Gram Panchayat has filed RTI petition to seek information regarding to the policy of National Rural Employment Guarantee Act (NREGA)[6]. This petition has questioned to know the number of job cards issued in the village, how many job card as been released as of now, who by this time should have got the cards, and who had not received it. As soon as this RTI was filed Panchayat authority has immediately released 40 job cards and promised to issue the other cards in few days. In the similar case that took place in the Kadambal district the same RTI was filed regarding the issue of Job Cards under NREGA policy as soon as the petition was filed immediately the authority has released 500 Job cards.The following are the few changes brought in by the RTI Act are enumerated below:

S.no	Without RTI	With RTI
1.	The authority was sluggish.	The authority became energetic and responsible
2.	The authority was inconsistent and lacked punctuality in their duties	The authority became consistent and punctual.
3.	The authority was not taking appropriate action on the complaint	All relevant officials started taking every complaint seriously
4.	No mechanism to seek information	Effective mechanism established to seek information.

Table 1: Impact of RTI

Therefore, it is evident that not only the information has empowered the citizen even the application to seek for the information as empowered the citizens.

RESTRICTION IN RTI ACT

Every Act is framed and enacted in such a way that it should balance two sides it should be very conscious that one side should not dominate the other side, there will be always the check and balances established in every Act established in India. The RTI Act, though it empowers the citizens and third party who is a non citizento seek for the information but it is limited with certain restriction as mentioned in the Act the information that tend to affect the dignity, sovereign function of India can’t be revealed. The Act also stated that certain information can’t be revealed, those all are mentioned in the Schedule II of the Act.the information those that are nowhere related to the person seeking it and no public activity or interest in it can also be ignored from furnishing it those information are known to be personal information In Girish Ramchandra Deshpande vs. Central Information Commissioner (2013)[7] The Bench expressed the view that an employee's performance within an organization is fundamentally a matter between the employee and the employer. Typically, these matters are categorized as 'personal information,' the release of which does not pertain to any public activity or interest. It was determined that disclosing such information would result in an unjustified invasion of that individual's right to privacy. Consequently, the Supreme Court further ruled that such information may only be disclosed if it serves a broader public interest. On one hand, the restriction limits the information seeker to requesting only the information itself, without allowing for inquiries about clarifications or the reasons behind decisions.

At the same time, Dr. Celsa Pinto vs. Goa State Information Commission[8] held the term “information” as outlined in the Right to Information Act does not encompass responses to inquiries such as “why”. The definition of information excludes answers to the question “why,” as this would equate to seeking justification for a specific action. Consequently, public information authorities are not obligated to convey to citizens the rationale behind a particular decision or inaction..

Therefore, RTI acts as a medium to deliver the information of public authority to citizen to enhance the transparency of the government function with certain limitation with it.

ADMISSIBILITY AND PROOF OF RTI DOCUMENTS

A law without sanctions is like a bell without a clapper[9], although the RTI Act was intended to combat corruption and promote transparency, it does not address the use of documents obtained under it as evidence in courts in accordance with the Indian Evidence Act, 1872. This has led to questions in various courts regarding the admissibility and method of proving these documents. This sub topic is going to have a spin off about the admissibility of information obtained in the form documents is admissible or not.

Section 63(1) defines secondary evidence as certified copies provided in accordance with the provisions of the Evidence Act. This must be interpreted alongside Section 76, which defines certified copies as copies of public documents held by a public officer, which a private citizen has the right to inspect. These copies must be accompanied by a certificate confirming they are true copies. The certificate must also carry the name, signature, and seal of the officer issuing the copy[10].Consequently, the two stipulations outlined in Section 76 are as follows: firstly, an individual must possess the right to examine a document; and secondly, there must be a certificate affirming that the document obtained is an accurate copy, accompanied by the particulars of the officer involved. The RTI Act serves as the overarching legislation governing the request for document inspection. The definition of the right to information encompasses not only the ability to receive copies but also the right to inspect documents[11].Thus, the first requirement is satisfied. Additionally, documents obtained under the RTI Act come with a letter from the Public Information Officer (PIO) confirming that the attached documents are true copies. These documents are stamped with the Officer's seal and a 'True Copy' mark. Therefore, the second requirement is also met, making documents received under the RTI Act, when pertaining to public records[12], eligible to be treated as certified copies of public documents under the provisions of the Evidence Act. However, this point was not accepted by the court at the first and subsequent cases the same was accepted by the court, In Bhaskar Rao v. KA Rama Rao[13], a single-judge bench of the Andhra Pradesh High Court noted, “None of the documents in question are certified copies; they are merely Xerox copies certified as true copies under the Right to Information Act. As such, true copies cannot be considered equivalent to certified copies under the Evidence Act.” The Court, however, did not explain the reasoning behind this conclusion or clarify the distinction between true copies and certified copies.

Subsequently the in the case of, Datti Kameswari v. Singam Rao Sarath Chandra[14] The Court in Datti Kameswari found that, “if a document is obtained under the Right to Information Act from a competent Authority”, it can be asked to be taken as a certified copy if the original satisfies the definition of public document.However, Datti Kameswari ruled out that the observations of the earlier court in Bhaskar Rao case. Further,In Narayan Singh v. Kallaram[15], at MP High Court, also took the same stand like AP court, concluded that true copies under the RTI Act are the same as “certified copies”.The Madhya Pradesh High Court, however, gave reasons for its conclusion. It referred to the definition of “right to information” under the RTI Act, which specifies the receipt of “certified copies” of documents, with no mention of true or attested copies. Additionally, the Court cited the definition of “certified copies” from Black’s Law Dictionary, which describes them as copies signed or certified as true by the officer holding the original document.

Therefore, copies of public documents obtained under the RTI Act qualify as certified copies as defined in Section 63(1) in conjunction with Section 76 of the Evidence Act. As determined, the Evidence Act permits these documents to be admitted as evidence without requiring additional oral corroboration.

ROLE OF DIGITAL PLATFORMS AND TECHNOLOGY IN RTI

Digital platforms and technology play a significant role in enhancing the effectiveness and accessibility of the Right to Information (RTI) Act.The Department of Personnel and Training has launched a web site[16], RTI online, with the URL www.rtionline.gov.in, for all Central Ministries and Departments. This is a service that allows Indian citizens to file RTI petitions and first appeals online to all Central Ministries/Departments. The prescribed RTI costs can be paid online. PIOs/FAAs can respond to RTI petitions and first appeals received online. As a result, candidates must give contact information as well as personal information such as gender, literacy or illiteracy status, and poverty level. According to the criteria, an applicant who claims to be below the poverty line must attach supporting paperwork to ensure that they don’t have to pay a fee. Then there’s a box where you can type out your request, as well as upload an attachment if there’s not enough room to explain what sort of information you want. An information seeker can submit a fee of Rs 10/- via internet banking through the associated banks using the website. In the first phase, this facility is available to Central Ministries/Departments/Apex Bodies only in 2014 post 2018 this online facility is available with all the State wise public authorities the list available in the guidelines mentioned in the website. Therefore, incorporating the digital medium into the filing of RTI has become popular across the country and it has been the successful E-Governance initiative of the respective state and future of RTI filling has became simple, effective and most time saving process.

JUDICIARY CONTRIBUTION IN ENFORCING RTI AND ITS PROVISIONS

The judiciary has played a pivotal role in enforcing the Right to Information (RTI) Act in India by interpreting its provisions, expanding its scope, and ensuring its effective implementation. In order to understand the effectiveness of a Fundamental Right it is important to analyze the various aspects in which the right has been given effect by the Judiciary. There are many key contributions of the judiciary in enforcing the RTI Act. A few landmark cases have been taken to highlight the various facets relating to Right to Information.

In the case of Bennett Coleman v. Union of India[17], is the first, that has recognized right to know as a Fundamental right and consequently the Supreme Court ruled that the right tofreedom of speech and expression guaranteed by Art. 19(1)(a) included the right to information.

In the case of State of UP v. Raj Narain[18], The Supreme Court stated that the Right to Information is part of the Right to Freedom of Speech and Expression provided by Article 19(1)(a) of the Indian Constitution. The court ruled that citizens have the right to know about the acts of public officials, and that this right is required to ensure transparency and accountability in governance. Overall, the Raj Narain case paved the way for India's Right to Information Act, 2005, and established the notion that citizens have a right to know how government entities operate.

In the case of Secretary, Ministry of I&B, Government of India v Cricket Association of Bengal[19], the Supreme Court held that the right to impart and receive information from electronic media was included in the freedom of speech.

In S.P. Gupta v. Union of India[20], the right of the people to know about every public act, and the details of every public transaction undertaken by public functionaries was illustrated by the Apex Court of India.

In People’s Union for Civil Liberties v. Union of India[21], The case was filed by the PUCL, which sought information about the alleged fake encounters by the police in the state of Gujarat, (CBI) refused to disclose the information, citing reasons of confidentiality. The case went to the Supreme Court, which observed that the Right to Information is a fundamental right under the Indian Constitution and held that citizens have a right to access information held by public authorities. The court also observed that transparency and accountability in governance are essential for promoting democracy and upholding the rule of law. The court directed the CBI to disclose the information sought by the PUCL and held that the Right to Information Act, 2002 was not adequate to ensure transparency and accountability in governance. The court emphasized the need for a comprehensive law to ensure the Right to Information and directed the government to enact such a law. In response to the Supreme Court's direction, the Indian government enacted the Right to Information Act, 2005, which provides a framework for citizens to access information held by public authorities. The Act has been instrumental in promoting transparency and accountability in governance and has enabled citizens to participate in the decision-making process of the government.

RECENT AMENDMENT TO RTI ACT 2005

 The RTI Act 2005 was amended in the year of 2019 namely RTI Amendment Act 2019, though there are no major changes in the Act, but there were few changes made to the former Act, the amendments are as follows:

Firstly, The RTI Amendment Act 2019 has made changes to the authority in deciding the term of holding the office of Chief Information Commissioner (CIC) and Information Commissioners (ICs) at the Centre and the State level to Central Government, previously it was five years or 65 years whichever gets complete at earliest.

Secondly, The RTI Amendment Act of 2019 empowers the Central Government to set pay, allowances, and other terms and conditions of service for CICs and ICs at the Central and State levels. Previously the salary of CIC’s and IC’s at central level were equivalent to the salary of Chief Election Commissioner and Election Commissioner and other working conditions of State Level CIC and were equivalent with the Chief Secretary of the state” respectively.

Thirdly, The RTI Amendment Act of 2019 has removed the advantages such as “pension or Retirement benefits conferred to the CIC and ICs at the Centre and State level” from prior government services.However,Before the Amendment Act, if the Chief Information Commissioner (CIC) or Information Commissioners (ICs) at the central or state level were already receiving a pension or retirement benefits from previous government service at the time of their appointment, their salary would be reduced by an amount equivalent to those benefits.

CONCLUSION

Anything that triggers or accelerates something for significant change it is known as catalyst, therefore it is an undisputed fact that RTI is a catalyst that accelerates the citizen to seek for the information to ensure that Government is functioning without any bias and thereby making them accountable and transparent. As said by Henery Clay[22], “Government is a trust and the officers of the Government are trustees and both the trust and the trustees are created for the benefit of the people.”  Every democracy relies on an informed public and transparent information, both essential for its proper functioning, curbing corruption, and ensuring that governments and their agencies are accountable to the people. To establish a practical system that allows citizens access to information held by public authorities, and to foster transparency and accountability in the functioning of these authorities, the Right to Information (RTI) is a fundamental right. A democracy holds little value if its citizens are unable to assess the performance of government operations, bureaucrats, and other officials acting on behalf of the state. For people to effectively evaluate government performance, they must be well informed about its policies, actions, and shortcomings. An informed public is essential for true participatory democracy and that is possible through RTI Act.

* Asst. Prof of Law, School of Law, Joy University, Tamilnadu

** Asst. Prof of Law, School of Law, Joy University, Tamilnadu

[1] S.P. Gupta v. Union of India (1993) 4 SCC 441

[2] Prabhu Dutt v. Union of India AIR 1982 SC 6

[3] Anjali Bhadrwaj  v. Union of India , 2019 SCC Online SC 205.

[4] Briefing Paper, Analyzing the Right to Information Act in India, CUTS International,  http://www.cuts-international.org/cart/pdf/Analysing_the_Right_to_Information_Act_in_India.pdf

[5] Ansari MM in a lecture entitled, “Impact of Right to Information on Development: A Perspective on India’s Recent Experiences”, delivered at UNESCO headquarter, Paris, France, May 15, 2008

[6] Smita. S, The Right to Information in India: Implementation and Impact, Volume 1, No. 1 Quarter IV 2010, Afro Asian Journal of Social Sciences,2010.

[7]Girish Ramchandra Deshpande vs. Central Information Commissioner, 1 SCC 212, (2012) 8 SCR 1097.

[8]Dr. Celsa Pinto vs. Goa State IC 2008 (3) AIR BOM R 343

[9] John Caldwell Calhoun was an American statesman and political theorist who served as the seventh vice president of the United States from 1825 to 1832.

[10]S 76, Indian Evidence Act 1872, Certified copies of public documents.

[11]S 2(j).Right to Information Act 2005

[12] Aditya Mehta, Admissibility and Proof of RTI Documents under the Indian Evidence Act, Article 5,  

   Volume 32 Issue 1, National Law School of India Review,2020.

[13]Bhaskar Rao v. KA Rama Rao 2010 SCC Online AP 898

[14]Datti Kameswari v. Singam Rao Sarath Chandra 2015 SCC Online Hyd 389 :AIR 2016 Hyd 112.

[15]Narayan Singh v. Kallaram 2015 SCC Online MP 281 : AIR 2015 MP 186

[16] S K Agarwal, Right To Information -A Guide, Transparency International India 2014.

[17]Bennett Coleman v. Union of India AIR 1973 SC 106

[18]State of UP v. Raj Narain, 1975 (004) SCC 0428 SC

[19]Government of India v Cricket Association of Bengal,1995(002) SCC 0161 SC

[20]S.P. Gupta v. Union of India, AIR 1982 SC 149

[21]People’s Union for Civil Liberties v. Union of India 2003(001)SCW 2353 SC

[22] 1832. Speech on the Public Lands.