After a three-year RTI battle, the Central Information Commission (CIC) has found “determined and deliberate resistance” to disclosure of information by the Municipal Corporation of Delhi (MCD) in a stray dog management case and imposed a ₹25,000 penalty.
It also awarded ₹10,000 compensation to the applicant and ordered proactive disclosure of records, including NGO payments, sterilisation and vaccination data.
The order referred to the Supreme Court’s May 19, 2026, verdict on the stray dog issue, which stressed the need to closely monitor the implementation of Animal Birth Control (ABC) measures through objectively verifiable data.
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The CIC said upfront public disclosure of information sought by the applicant would facilitate regular monitoring of ABC measures and promote transparency and accountability.
The case arose from a December 2022 RTI application filed by Akshay Kumar Malhotra seeking information on animal welfare organisations engaged by the MCD, sterilisation and vaccination of stray dogs, dog shelters, complaints received by authorities and expenditure incurred on such activities.
The commission said the information sought related to implementation of the animal birth control programme, payments made to NGOs, functioning of animal shelters, monitoring mechanisms and expenditure of public funds, much of which ought to have been proactively disclosed under Section 4(1)(b) of the RTI Act.
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During the show-cause proceedings, the CIC observed that the respondents had “clearly evaded providing complete and relevant information on each of the queries and instead asked the appellant/complainant to approach the NGOs who executed the work. Obviously, such NGOs will tell him that they are not a public authority, and they will turn down any request from him,” it said.
The commission further observed that despite its earlier directions, the respondent failed to place the information in the public domain and held that “the PIO stands in continued violation of hon’ble Apex Court’s orders for upfront public disclosure as mandated under section 4(1)(b) of the RTI Act”.
“Respondent’s determined and deliberate resistance to disclosure of information to the appellant/complainant and also for putting it particularly in the public domain is established beyond any doubt,” the commission said.
The CIC directed the MCD commissioner to ensure proactive disclosure of information relating to animal birth control programmes, sterilisation and vaccination data, payments made to NGOs, contracts, monitoring committee details, shelter and kennel information, complaints received and action taken reports.
The commission also took note of the applicant’s allegations that disclosure of his personal details to third parties had resulted in intimidation and harassment while he pursued information related to stray dog management in his locality.
It observed that proactive disclosure of such information would reduce the possibility of “intimidation and harassment of individual information seekers”.
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Awarding compensation of ₹10,000, the commission said the applicant had been deprived of timely access to information concerning “public health, public safety and expenditure of public funds” affecting his locality and was compelled to pursue first appeal, second appeal and show-cause proceedings for more than three years.
“The conduct of the respondent has resulted in unnecessary litigation and avoidable hardship to the appellant,” the commission said.
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