Krishnakumar,
The
RTI Act provides for Penalty under Sec 20(1) and Disciplinary Action under Sec 20(2) against the
PIO for various reasons listed therein.
The
PIO is not responsible for not implementing Sec 4 in a PA. He is only responsible for not providing information when asked about it. He will coolly reply "the information asked is not available on record".
As per my understanding it is only the Administrative Head of a PA who is responsible for implementing Sec 4.
And, as all of us know, there is no provision in the
RTI Act for penalising or taking disciplinary action against the administrative head.