1. Suo Moto Clause (Sec 8): A clause relating to suo moto dissemination of information should be introduced on the lines of Section 4 (b) of Delhi Right to Information Act.
2. Exemptions (Sec 5): The information relating to Governor's constitutional function & Centre State relation should be made public after final decision has been taken on the files. The information should not be kept out of public scrutiny as presently proposed.
3. Penalty (Sec 9): This Section in its present form is impractical from the point of view of implementation. It does not address concerns like who will initiate disciplinary proceedings, whether he will do this suo moto or on a complaint from the public, in how much time will the penalty be imposed etc. Draft Maharastra Bill provides an answer. It states that the issue of penalty will be decided by the appellate authority while hearing appeals, after giving an opportunity of being heard to the govt. servant within 30 days. So, penalty will be imposed on the basis of the order of appellate authority. In addition, disciplinary proceedings will also be initiated against the official under the conduct rules & the official will be punished in accordance with the conduct rules also.
   Another issue in penalty clause is that no penalty has been provided for giving false information, incomplete information, irrelevant information and unjustifiable rejection. For each of these guilts, there should be a penalty of Rs 2000 as provided in Draft Maharastra Act.
4. Appeal (Sec 7):
   1. The higher authority with whom the first appeal will lie should not be the direct boss of the competent authority. He should be some external authority.
   2. It is written that 'endeavour' should be made to decide appeal in 45 days. The word 'endeavour' should be removed. It should be provided that appeal should be decided within 30 days & not exceeding 45 days under any circumstances.
5. Low Fees:
   1. The third proviso to Sec 4(a) should be removed. It is prone to misuse. How the applicant will finally use the information is of no significance to the govt.
   2. There should be no application fees for inspection of records or for filing an application. There should be only Re 1 per page photocopying charges for supplying information.
6. If the application is to be rejected, the rejection order should be passed within 7 days (and not 30 days) as mentioned in Sec. 4 (b).
7. In some states an affidavit has to be filed to seek information. This should not happen. There should be a very simple form prescribed to apply for seeking information.
8. The phrase within brackets in section 2 (c) should be removed.
9. The competent authority should be notified by the government & not individual organizations. The word organisation should be removed from Section 2 (a). The competent authority declared in any government department should be a sufficiently senior officer.

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