How to File RTI with Coal India for Mining Operations, CSR Spending and Employee Matters

Coal India Limited (CIL) is India's largest coal mining company and a Maharatna Central Public Sector Undertaking (PSU) under the Ministry of Coal. The Government of India holds approximately 63% of CIL's equity, making it squarely a public authority under Section 2(h) of the RTI Act, 2005. CIL and all its subsidiary companies are therefore fully subject to RTI obligations.

RTI is a powerful tool in the coal sector: for a mine worker contesting a transfer or tracing a CMPF pension, for a community displaced by mine expansion seeking R&R entitlements, for a citizen asking how CSR money was spent in their district, and for a researcher or journalist tracking coal block allocations and environmental compliance.

CIL and Its Subsidiaries

CIL operates through eight wholly owned subsidiary companies, each responsible for mining operations in specific states. For most operational matters — a specific mine, a local employee grievance, a CSR project in a district — the RTI should be directed to the relevant subsidiary. CIL headquarters in Kolkata handles policy, aggregate data, and decisions made at the CIL board level.

NLC India Limited (formerly Neyveli Lignite Corporation) and Singareni Collieries Company Limited (SCCL) are separate companies and are not CIL subsidiaries.

What Can You Achieve with RTI to Coal India?

CMPF vs EPFO: A Critical Distinction for Coal Mine Workers

Coal mine workers are governed by a completely separate provident fund law — the Coal Mines Provident Fund and Miscellaneous Provisions Act, 1948 — and are excluded from EPFO's coverage. This is one of the most common sources of confusion when filing RTI.

If you are a coal mine employee or a retired coal mine worker, any PF balance query, contribution dispute, pension sanction, or pension amount dispute must go to the CMPF Commissioner's Office in Dhanbad — not to any EPFO Regional Office. Filing with EPFO will result in a transfer or rejection.

CSR Spending: Using RTI for Local Accountability

CIL and its subsidiaries are among the largest CSR spenders in India, with a statutory obligation to spend 2% of average net profits on CSR activities under Section 135 of the Companies Act, 2013. The CSR activities must be prioritised in the areas around their mining operations — the same communities often affected by land acquisition, displacement, and pollution.

Despite this, CSR implementation is often opaque at the village and district level. RTI can expose:

1. Total CSR obligation vs actual spend: Whether the company met its 2% obligation, or fell short and transferred funds to the Unspent CSR Account (required since the Companies (Amendment) Act, 2019)
2. Project-wise allocation: Which projects were sanctioned in which district, with amounts allocated
3. Implementing agencies: Whether CSR was implemented directly or routed through trusts/NGOs — and which agencies
4. Utilisation certificates: Whether funds released to implementing agencies were properly utilised and reported
5. Unfulfilled commitments: CSR projects announced but not executed or abandoned midway

Specific RTI questions for CSR transparency:

• List of all CSR projects for financial year YYYY-YY in District — project name, implementing agency, amount sanctioned, amount released, status
• Copy of the Annual CSR Action Plan for YYYY-YY under the Companies (CSR Policy) Rules, 2014
• Whether any amount was transferred to the Unspent CSR Account under Section 135(6) — if yes, the amount and the projects for which it was earmarked
• Minutes of the CSR Committee meeting(s) where the projects for YYYY-YY were approved

Land Acquisition and Displaced Communities

Coal mining requires large tracts of land, often in areas with dense tribal and agricultural communities. Land for coal mining is acquired primarily under two laws:

1. Coal Bearing Areas (Acquisition and Development) Act, 1957 (CBA Act): A special law enabling the Central Government to acquire land for coal mining by notification. Less procedurally elaborate than LARR Act — no mandatory SIA, lower consent thresholds for state acquisitions.
2. LARR Act, 2013: Applies where CBA Act is not invoked, or where additional R&R protections apply. Requires Social Impact Assessment, consent in certain categories, and robust R&R entitlements.

CIL's own Resettlement and Rehabilitation Policy commits to providing at least one job (or annuity in lieu) to each displaced family, a house plot or subsidised house, and subsistence allowances.

RTI questions for displaced communities:

• Copy of the CBA Act notification / LARR Act Section 4 notification for the acquisition involving village/survey nos.
• Compensation rate determined per unit area — basis and calculation
• List of landowners / affected families for whom compensation was determined — names, survey numbers, amounts, and payment status
• R&R entitlement list for displaced families — employment provided (names, dates, mines), house/plot allotted, subsistence allowance paid
• Number of families from village still awaiting employment or resettlement as of date

Where to File

File on rtionline.gov.in:

1. Select Ministry of Coal
2. Choose Coal India Limited (for policy/aggregate matters) or the specific subsidiary (ECL, BCCL, CCL, WCL, SECL, MCL, NCL, NEC) for operational/local matters
3. For CMPF matters: select Coal Mines Provident Fund Organisation (listed separately)
4. Draft your application with the mine name, employee details, or CSR/land acquisition reference as applicable
5. Pay ₹10 online. BPL cardholders are exempt
6. Submit and note your registration number

For environmental clearance violations: an additional or simultaneous RTI with the Ministry of Environment, Forest and Climate Change (MoEFCC) (for national-level EC) or the State Pollution Control Board (for state consent conditions) will give you the compliance reports and any show cause notices.

For safety violations: file RTI with the Directorate General of Mines Safety (DGMS), under the Ministry of Labour and Employment — DGMS is the statutory regulator for mine safety and holds inspection reports, accident inquiry reports, and closure orders.

What Specific Information Can You Ask For?

Employee service matters:

1. Transfer order / promotion order for Employee ID XXX — date, authority, and criteria applied
2. Seniority list as on date for the cadre / designation of the above employee at Mine / Area
3. Departmental enquiry record for Employee ID XXX — charges, enquiry officer's report, final order

CMPF (file with CMPF Commissioner's Office, Dhanbad): 4. CMPF account balance for Account No. XXX — employer's share, employee's share, total 5. Employer contribution record for the last 24 months — monthly amounts and whether any are in arrears 6. Status of CMPF pension application — date received, pension amount determined, date from which payable

CSR spending: 7. Project-wise CSR expenditure in District for FY YYYY-YY — project name, agency, amount sanctioned, released, and completion status 8. Copy of the Annual CSR Action Plan and the CSR Committee approval minutes for YYYY-YY 9. Unspent CSR amount transferred to the Unspent CSR Account — project-wise details

Land acquisition and R&R: 10. CBA Act / LARR Act notification and compensation rate for the acquisition at village / survey nos. 11. R&R entitlement list and fulfillment status for displaced families — employment, house/plot, subsistence allowance

Coal block allocation: 12. Allocation order and current production data for coal block Block Name, State 13. Royalty / revenue paid to State government for the last 3 years for this block

Environmental clearance compliance: 14. EC conditions and latest compliance report for Mine Name — air quality, water body, land reclamation, coal dust 15. Any Show Cause Notice issued to Mine Name by MoEFCC / SPCB — copy of notice and status

Appeals

First Appeal (Section 19(1)): File with the First Appellate Authority (FAA) at CIL or the relevant subsidiary within 30 days of the date of decision or expiry of the 30-day response period, whichever is applicable. For CMPF matters, the FAA is at the CMPF Commissioner's Office.

Second Appeal (Section 19(3)): File with the Central Information Commission (CIC) within 90 days. Coal India Limited, all its subsidiaries, and the CMPF Commissioner's Office are Central Government public authorities — second appeal goes to the CIC, not any State Information Commission.

For R&R or land acquisition disputes involving state-level Land Acquisition Collectors, the second appeal for the Collector's RTI goes to the relevant State Information Commission.