I would call this a foolish decision. The AA himself has the powers to initiate action against his subordinate if he disobeys his orders or rather not comply with his orders. Then why should he initiate action seeking recommendation of the
CIC to initiaate action ? If the AA desire that the information need to be provided, no
PIO will ever dare to refuce the information. The whole episode is a unified drama of
PIO and AA. The
PIO get 30 days. It takes minimum of another 30 days for his reply of refusal or denial to reach the applicant, prepare the First Appeal and make it reach the AA. The AA get 30 to 45 days. Altogether it involve more than 100 days making the entire time-frame a mockerry.