RTI IN OTHER COUNTRIES

This article is written by Samriddhi Mishra of 2nd semester of National Law University Odisha, an intern under Legal Vidhiya

ABSTRACT

Right to information is now recognised as one of important rights in a democracy.

Access to information allow more accountability and increases transparency. It is one of strong check against corruption. More than 100 countries in a world right now have law or regulation governing access to information of public authorities. This right was first time recognised in Sweden. After Sweden number of countries recognised this right. This law is now considered as part of many countries’ constitution and is also part of law in some non-governmental countries. This article seeks to understand right to information laws in different countries around the world its growth across the world.

Keywords: right to information, access to information. Freedom of information, accountability, transparency

INTRODUCTION

“Where a society has chosen to accept democracy as its creedal faith, it is elementary that the citizens ought to know what their government is doing.” -Justice P N Bhagwati

It is said that “knowledge is power”. This holds true when citizens want to hold their government accountable. Knowledge of acts done by their government allows them to question the efficacy of their actions. Access to information about the acts done by a public body helps citizens make informed judgements and allows for public participation. This strengthens the system of checks and balances. 

The Right to Information Act of 2005 gave Indian citizens right to know regarding public bodies and their workings. After promulgation of this act, access to information from public agencies became a statutory right for citizens.

Access to government information increases transparency and accountability in the administration. It creates a system where the informed public acts as the best judge of the administration and checks on corruption. The right to know, protected by the Right to Information Act, is sine qua non for a healthy democracy. The right to know has allowed investigative journalists, RTI activists, and any curious citizenry to ask questions and demand answers.

This allows citizens to have access to facts and decisions that directly affect their lives.

This lifts the veil of secrecy from public administration and makes the administration more transparent, which in turn increases public awareness about the workings of the administration and makes the administration more accountable as a result. 

This truly encompasses the spirit of democracy.

This right is now recognised as one of the most important rights in democracy, with many countries recognising it as a constitutional right. Over the last century, the importance of the “right to know” has come to be established as one of the indispensable rights of citizens. 

As of now, over 100 countries recognise this right. The growth of this right was slow and had many struggles; it still suffers from loopholes, and not every nation’s legislation or policy is strong enough, but recognition of this act is promising.

RTI AROUND THE WORLD

Article 19 of the ICCPR and the UDHR both recognize this right to as integral part of right of freedom of expression other largely recognised and cherished right. Both read as-

“Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive, and impart information and ideas through any media and regardless of frontiers.”[1]

To emphasize the value of information freedom, UNESCO observes the International Day for Universal Access to Information on September 28. [2]

The SDG goals acknowledge the importance of this right to achieve a human society, as idealized by Sustainable Development Goal (SDG) number 16: ‘Peace, Justice and Strong Institutions’. Target 16.10 urges all participating states to “ensure public access to information and protect fundamental freedoms, in accordance with national legislation and international agreements”.[3]

126 nations currently have access to information laws in place, and 96 states have the right expressly recognised in their constitutions, according to the Article 19 Global Right to Information Maps. This indicates that 91% of the world’s population resides in a nation where formal information requests can be made to the government or a local authority.[4] 

As per UNESCO, 132 UN member states have some form of legal guarantee as of August 2021.[5] The right is increasingly recognised in countries, even in non-democratic ones.

This means citizens of most countries around the world have access to information held by public bodies and the government.

This right took centuries to evolve. The first country to establish a law on RTI law was Sweden. Sweden passed the world’s first Right to Information Act In 1776, Sweden passed the “Freedom of the Press Act”. This legislation established press freedom, which includes the right to publish and distribute information about the executive branch, judicial system, and parliament. Recognising that press freedom depends on access to information, the law, which is a part of Sweden’s constitution, states that “to that end, free access should be allowed to all archives, for the purpose of copying such documents in loco or obtaining certified copies of them.”[6]

Many nations thereafter adopted this historic act as their own. Following Sweden, many other nations passed the same law. Finland enacted the law in 1951, followed by Denmark and Norway in 1970, Austria in 1973, the United States in 1974, Canada in 1977, France, the Netherlands, and Australia in 1978, the United Kingdom in 1989, and India in 2005.[7]

Only 19 nations had implemented what are now known as RTI legislation by the year 1995. In the 15 years between 1980 and 1995, fewer than one new RTI legislation were passed year on average. The rate, however, more than quintupled during the following 15 years and is destined to maintain that pace as 2015 approaches due to the revolutions in Central and Eastern Europe in the 1990s and democratization efforts in other countries. In addition, although the first 19 nations, with the exception of four, were all Western democracies, the next 79 nations were spread out over every continent.[8]

In 1995, Western democracies accounted for the great majority (almost 80%) of the countries with RTI legislation in place. Over the next ten years, RTI legislation were enacted in 20 Eastern European nations, making up over half of all new laws that were enacted. By 2005, only a few European countries did not have RTI legislation, due to the regulations that six other Western countries also approved. Between 1995 and 2005, there were around 10 new laws added to each of the Americas and Asia. With only four new RTI legislation added during this time, Africa made less progress than other continents. [9]

There are currently few RTI laws in the Middle East and North Africa after Jordan passed the first one in the area in 2007. Since 2005, Asia and the Americas have advanced more or less quickly (each with seven or eight new laws), whereas Africa seems to be gaining ground with eight new laws. The second half of the 20th century saw a genuine remarkable increase in the number of these legislation.[10]

Right to information in Europe

Transparency is one of the most important principles in the EU.

Under Article 15 of the Treaty on the Functioning of the European Union, citizens and residents of EU countries have a right of access to the documents of the European Parliament, the Council, and the European Commission.[11]

As mentioned above, Sweden was the first country to adopt the right to information law. Many scholars, like Jean-Jacques Rousseau, were talking about public accountability and transparency. Many countries adopted the law to provide access to government information to the general public. After Sweden, it took almost two centuries for Finland to adopt the law.

In 1951, Finland became the next country to adopt this law. 

France and the Netherlands adopted a freedom of information law in 1978. The right to free access to budgetary information was outlined in Article 14 of the Declaration of Human Rights of 1789. Anyone can access documents of government agencies under the “1978 Law on Access to Administrative Documents.”[12]

The Netherlands passed a in 1978. The previous law, was repealed in 1991. According to the Act, anyone may ask for information regarding an administrative authority or private entity performing public services for government. The government body has two weeks to reply. Advisory committee recommendations must be made available to the public within four weeks. 

Denmark also joined the other Nordic countries in implementing a. An act from 1865 permitted losers in a legal dispute to view administrative records. The “1970 Act on Access of the Public to Documents in Administrative Files” established a comprehensive freedom of information programme, building on the 1964 adoption of the first general (but constrained) act on access to information. Government records can be accessed under the authority of the “1985 Access to Public Administration Files Act.” [13]

These initial laws were adopted as a means to regulate communication between public authorities and citizens.

Only a small number of nations had access to information or freedom of information (FOI) laws by the end of the 1980s those small nations were the Nordic nations with Italy, France and Netherlands. By 1990, only Finland and Sweden recognised this right as a part of their constitutions. Norway followed in 2004.[14]

The primary driving force for the creation of this law was the collapse of the Berlin Wall. The definition and enlargement of the right to access information came about as a result of a robust and well-planned push back response from civil society to the way authoritative government were practicing maintaining high degree of secrecy over all public agencies’ information. This response was a part of chain reaction after the fall of the Berlin wall that divided Germany into two. The lack of access to information in the Soviet bloc led to demand of access to information as a right.

This occasion sparked the call for information access to be recognised as a fundamental right. All eight former communist nations that joined the European Union on May 1, 2004, as well as Romania and Bulgaria, that became part of EU on January 1, 2007, Croatia, that became part of EU on July 1, 2013, all had access to information laws in place at the time. Prior to joining the EU, Croatia had had a law governing access to information for ten years. Each of these eleven countries’ constitutions also establishes the right.[15]

After almost 20 years of campaigning, the FOIA was adopted in Britain in November 2000. The Act grants anyone the right to access information held by a wide range of

over 100,000 distinct public authorities. There is a separate legislation for Scotland public authorities, that are governed by the “Freedom of Information (Scotland) Act 2002”, the FOIA 2000 implements freedom of information legislation across the United Kingdom. The response from the authorities must come within 20 working days.[16]

Now almost all of Europe has laws allowing access to information, except Belarus.

RTI in South America

The democratization of post-communist eastern Europe also influenced the growth of this law in Latin American countries. Many countries in South America have adopted RTI laws.

Colombia became the first nation in Latin America to enact a law governing public access to information as early as in 1985.[17]

Despite the fact that Latin American democracies came after North America in the 2000s, it is generally agreed that their laws have improved upon those in both countries. Mexico, Chile, Brazil, and Uruguay have more comprehensive laws ensuring access to information, and they are all applicable at both the national and local levels of government. The majority of Latin American nations currently have freedom of information legislation. Several of these nations are even regarded as having some of the finest laws in the world.[18] 

Cuba is among those that have no law, regulation, or decree for access to information.

One of the first nations to pass a complete freedom of information law was Colombia, which did so in 1985, years before the majority of other long-standing democracies. Amendments made in 2011 and again in 2014 significantly reinforced Colombia’s trailblazing “Law 57.”[19]

Lessons from their Colombian and Mexican predecessors as well as other international models, such the ground-breaking South African constitution of 1996 and the U.S. Act of 1966, were included into the more recent access to information laws in Chile (2008) and Brazil (2011).[20]

RTI in North America

In the US, after World War II, a law governing information access was created. Following the Watergate incident, this law was strengthened even more. In 1966, the “Freedom of Information Act” (FOIA) was passed, and it became law in 1967. It has undergone several significant revisions, most recently in 1996 with the passage of the Electronic Freedom of Information Act. Any person or group may request to access records held government agencies under the law, regardless of citizenship or place of origin. Agencies also include executive and military departments, government enterprises, and other organizations that carry out official functions. Agencies also include Congress, the judiciary, and the President’s personal White House personnel, such as the National Security Council. Government agencies must reply within 20 working days.

Some state and district governments also have additional laws to promote transparency and accountability. The USA also has a practice of declassifying records. Laws relating to this are also called sunshine laws in the USA.[21]

Under the 1983 Access to Information Act, permanent residents of Canada, as well as other Canadian citizens and corporations, have the right to request and obtain copies of records kept by governmental entities. Within 15 days, the institution must respond. 

The 1997 Mexican Constitution’s Article 6 states, in part, that “the State guarantees the right to information.” President Fox signed the “Federal Transparency and Access to Public Government Information Law “approved by Parliament. The law became operative in June 2003. Anyone can ask for information from government agencies, independent constitutional bodies, and other governmental entities. Requests must be answered by agencies in 20 working days.[22]

“Ley Federal de Transparencia y Acceso a la Información Pblica Gubernamental” of Mexico from 2002 is regarded as a model for such legislation because of its expansive mandate and its implementation provisions, which include independent funding and legal standing for INAI, the National Access to Information Institute, that is responsible for the execution of the law.[23]

RTI in Africa

In accordance with the African Charter on Human and Peoples’ Rights, the African Commission on Human and Peoples’ Rights is required to “cooperate with other African and international institutions concerned with the promotion and protection of human and peoples’ rights.” One of the rights protected by the Charter is the right to information, as stated in Article 9(i), which states that “Everyone shall have the right to receive information.” The Special Rapporteur on Freedom of Expression and Access to Information in Africa’s mission is fundamentally based on this right.[24]

 Many countries in Africa have made access to information a part of their constitutions.

Zimbabwe, Liberia, Rwanda, Uganda, Sierra Leone, Nigeria, Niger, Tunisia, Ethiopia, Angola, Guinea, South Africa, Tanzania, Kenya, Côte d’Ivoire and Rwanda are among the African nations having a law to access information. By 2021, 23 states in Africa will enjoy the right to information.

Most nations in the East African Community (EAC) have laws governing how information about public bodies is to be made available to general public. Access to information laws were first adopted by Uganda in 2005, then by Rwanda and South Sudan in 2013, and by Kenya and Tanzania in 2016. In 2011, nearly six years after the ATI law in Uganda was enacted, regulations were passed to give it effect.[25]

To achieve the constitution’s information availability to public, Kenya passed the FOI Act. RTI legislation. Most recent member of the sub-region to adopt an ATI law was Rwanda. The 2013-passed law has received praise for, among other things, conforming to some international best practices standards including its reach, reasonable costs, and specific guidelines for proactive disclosure.

In Burundi, there is no legislation governing access to information. Information freedom is not entirely guaranteed by the nation’s constitution. The ‘gold standard’ in Africa for access to information laws is South Africa’s, but the country’s residents don’t seem to have a high need for information, and bureaucratic compliance is poor.

South Africa RTI law is one step ahead as it includes private bodies along with public bodies in the ambit of RTI.[26] 

Many African countries have regulations to control access to information. Kuwait and Saudi Arabia are among the countries that have most recently made regulations for public access to information.[27]

RTI in the Asia-Pacific region.

Most countries in Asia have access to information laws. With India having one of the most praised laws in the world. In 2002, Pakistan became the first South Asian country to have an RTI law. China is one of the major Asian countries that only has a regulation but no law governing information access to public.

Asia has some of the most progressive RTI laws in all nations around the world, including in India and Indonesia. These nations have developed progressive access and enforcement procedures.[28]

Some countries, like Japan and Thailand, were pioneers and leaders in the right to information but now have considerably out-of-date laws that require urgent updating.

Others, like the Philippines, have long debated, promised, and drafted access to information legislation but continue to be opposed to it. Sri Lanka recently drafted legislation in 2016.

Last but not least, there are countries like Laos, Malaysia, Myanmar, and Vietnam that maintain a tight hold on information that is under official control, seeing it as government property and refusing to let the public access it.[29]

Laws pertaining to the freedom of information have been widely adopted in the Asia-Pacific area. Today, a wide range of nations, including China, India, Indonesia, and the Cook Islands, have enacted comprehensive legislation or regulations that guarantee the right to access information. Some nations, like Indonesia, Mongolia, and Nepal, explicitly include the right to knowledge in the language of their constitutions. [30]

Although Australia more recently revised the law to follow best practices in the field of freedom of information, Australia and New Zealand were the first nations in the region to enact RTI laws as early as 1982.

Thailand came next in 1997, then Korea in 1996, and Japan in 1999. After the new wave of the freedom of information movement arose in the 1990s, the majority of Asian nations implemented RTI legislation after 2000. The much-appreciated RTI legislation that India adopted in 2005 has either served as a template for other laws that have been implemented afterwards (like Bangladesh’s) or as a standard for NGOs that advocate for changes to or adoption of their national laws.[31] 

Some nations don’t have RTI laws that adhere to international norms, and others have antiquated rules that haven’t been updated to meet contemporary criteria.

Overview of Laws from Around the World

Though most countries around the world today have the RTI laws, most of the laws have provisions for access to public bodies information. Many of these laws have limits on the time given to respond to the information asked for. 

Globally, the majority of legislation is largely similar. This is in part due to the laws of a select few nations—mostly those that were enacted early—having served as examples. The most significant statute has likely been the US FOIA. The national, provincial, and state laws of Canada and Australia are well-known among nations with a common law history.

The right for anyone to request materials held by public authorities and other governmental organizations is the most fundamental component of all FOI legislation. It can also be described as information, records, or papers. As computers supplanted paper file systems, the definitions differed, and several laws created access gaps.

In general, almost all governmental entities are covered by the legislation. This may also include local and regional entities, depending on the style of government. Courts, legislatures, and security and intelligence services may not be subject to coverage in some nations.

In almost all legislation, there are a number of common exclusions. These include safeguarding personal privacy, business secrecy, law enforcement, and maintaining public order, as well as internal conversations and the preservation of national security and international relations. For at least some of the rules, the majority of laws demand that harm be established before the information can be suppressed. Generally speaking, the criteria for harm differ based on the kind of information that has to be secured. The highest level of protection is often given to national security, internal decision-making protection, and privacy. Records of Cabinet meetings and materials given to the Cabinet for decisions are often omitted in parliamentary systems.

There are several procedures for appealing decisions and enforcing laws. These consist of judicial reviews, administrative reviews, and reviews conducted by administrative or judicial authorities.

These many approaches have widely varying degrees of efficacy. The countries that have established an external watchdog, such as an ombudsman or information commissioner, are often more transparent.

Some problems that prevent the best utilization of these resources are lack of execution, excessive fees asked for accessing information, a wide range of exemptions, making the process cumbersome, or making laws to prevent access to information.

CONCLUSION

It is said- “Sunlight is the best disinfectant.” An aware public is best to check on misuse of power and ways to keep democracy healthy. And for an informed public, the free flow of information is essential.

Laws governing access to information or the right to information are a means to an informed populace, with accountability and transparency as the ultimate goals. As of now, more than 100 countries have laws, regulations, or decrees that make provision for access to public information.

Many countries in the world have recognised this as a part of their constitution.

Sweden was the first country to adopt such law. After Sweden, the next law was adopted by Finland. The Nordic countries led the movement for RTI laws. 

This right over the years is now recognised as part of human rights and is even adopted by a few non-democratic countries too.

This large-scale acceptance of RTI laws is a cause for celebration, but there are still limitations in these laws preventing their best utilization. Our focus should be on filling the loopholes present in the law and recognising the possibilities of expansion in the scope of the law. Consider how, for instance, the law in South Africa went a step further to cover private organizations under the purview of the law on access to information.
REFRENCES

1. International standards: Right to information, Article 19 available at https://www.article19.org/resources/international-standards-right-information/ last seen on 22 may 2023
2. Infographic: Progress on the right to information around the world, Article 19 available at https://www.article19.org/resources/infographic-progress-on-the-right-to-information-around-the-world/ last seen on 22 May 2023
3. UNESCO, to recovery and beyond: 2021 UNESCO report on public access to information (SDG 16.10.2),13 (2021) available on https://unesdoc.unesco.org/ark:/48223/pf0000380520 last seen on 22 May 2023
4. History of Right of Access to Information, Access Info Europe available at https://www.access-info.org/2009-07-25/history-of-right-of-access-to-information/ last seen on 21 May 2023
5. Toby Medel,Right to Information RECENT SPREAD OF RTI LEGISLATION, World Bank Group available at https://documents1.worldbank.org/curated/zh/414481468180551330/pdf/98719-WP-P118353-Box393176B-PUBLIC-Recent-Spread-of-RTI-Legislation.pdf last seen on 21 May 2023
6. Helen Darbishire, Critical perspectives on freedom of expression: Ten Challenges for the Right to Information,5 in the Era of Mega-Leaks The United Nations and Freedom of Expression and Information Critical Perspectives Editors: (Tarlach McGonagle,2015) available at https://www.access-info.org/wp-content/uploads/CriticalPerspectivesonRightofAccesstoInfo_HelenDarbishire.pdf last seen on 21 May 2023
7. Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023
8.  Helen Darbishire, Critical perspectives on freedom of expression: Ten Challenges for the Right to Information,5 in the Era of Mega-Leaks The United Nations and Freedom of Expression and Information Critical Perspectives Editors: (Tarlach McGonagle,2015) available at https://www.access-info.org/wp-content/uploads/CriticalPerspectivesonRightofAccesstoInfo_HelenDarbishire.pdf last seen on 21 May 2023
9. Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023
10. UNESCO Office Montevideo and Regional Bureau for Science in Latin America and the Caribbean, Access to information: lesson from Latin America (2017), available at https://unesdoc.unesco.org/ark:/48223/pf0000249837 last seen on 21 May 2023
11. Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023
12. Horsenyo Hator, Simon. (2021). RTI IN AFRICA. 1, available at https://www.researchgate.net/publication/350974824_RTI_IN_AFRICA last seen on 21 May 2023
13. Comparative Analysis of Access to Information Legislation in East Africa, CIPESA.org available at https://cipesa.org/wp-content/files/reports/RTI-analysis_Rwanda-Updated.pdf last seen on 22 May 2023
14. Kenya: Realising the Right to Information, Article 19 available at https://www.article19.org/data/files/medialibrary/38388/Kenya-RTI-for-web.pdf last seen on 22 May 2023
15. UNESCO, to recovery and beyond: 2021 UNESCO report on public access to information (SDG 16.10.2),13 (2021) available on https://unesdoc.unesco.org/ark:/48223/pf0000380520 last seen on 22 May 2023
16. Article 19, Asia Disclosed: A Review of the
17. Right to Information across Asia (2015) available at https://www.article19.org/data/files/medialibrary/38121/FINAL-Asia-Disclosed-full.pdf last seen on 21 May 2023

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[1]International standards: Right to information, Article 19 available at https://www.article19.org/resources/international-standards-right-information/ last seen on 22 may 2023

[2]Idib

[3]Idib

[4]Infographic: Progress on the right to information around the world, Article 19 available at https://www.article19.org/resources/infographic-progress-on-the-right-to-information-around-the-world/ last seen on 22 May 2023

[5]UNESCO, to recovery and beyond: 2021 UNESCO report on public access to information (SDG 16.10.2),13 (2021) available on https://unesdoc.unesco.org/ark:/48223/pf0000380520 last seen on 22 May 2023

[6]History of Right of Access to Information, Access Info Europe available at https://www.access-info.org/2009-07-25/history-of-right-of-access-to-information/ last seen on 21 May 2023

[7]Toby Medel,Right to Information RECENT SPREAD OF RTI LEGISLATION, World Bank Group available at https://documents1.worldbank.org/curated/zh/414481468180551330/pdf/98719-WP-P118353-Box393176B-PUBLIC-Recent-Spread-of-RTI-Legislation.pdf last seen on 21 May 2023

[8]Ibid

[9]Ibid

[10]Ibid

[11]Helen Darbishire, Critical perspectives on freedom of expression: Ten Challenges for the Right to Information,5 in the Era of Mega-Leaks The United Nations and Freedom of Expression and Information Critical Perspectives Editors: (Tarlach McGonagle,2015) available at https://www.access-info.org/wp-content/uploads/CriticalPerspectivesonRightofAccesstoInfo_HelenDarbishire.pdf last seen on 21 May 2023

[12]Ibid

[13]Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023

[14] Helen Darbishire, Critical perspectives on freedom of expression: Ten Challenges for the Right to Information,5 in the Era of Mega-Leaks The United Nations and Freedom of Expression and Information Critical Perspectives Editors: (Tarlach McGonagle,2015) available at https://www.access-info.org/wp-content/uploads/CriticalPerspectivesonRightofAccesstoInfo_HelenDarbishire.pdf last seen on 21 May 2023

[15]Ibid

[16]Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023

[17]UNESCO Office Montevideo and Regional Bureau for Science in Latin America and the Caribbean, Access to information: lesson from Latin America (2017), available at https://unesdoc.unesco.org/ark:/48223/pf0000249837 last seen on 21 May 2023

[18]Ibid

[19]Ibid

[20]Ibid

[21]Commonwealth Human Rights Initiative,Freedom Of Inforamtion around the world 2006,(2006) available at https://www.humanrightsinitiative.org/programs/ai/rti/international/laws_papers/intl/global_foi_survey_2006.pdflast seen on 21 May 2023

[22]Ibid

[23]Ibid

[24]Horsenyo Hator, Simon. (2021). RTI IN AFRICA. 1, available at https://www.researchgate.net/publication/350974824_RTI_IN_AFRICA last seen on 21 May 2023

[25]Comparative Analysis of Access to Information Legislation in East Africa, CIPESA.org available at https://cipesa.org/wp-content/files/reports/RTI-analysis_Rwanda-Updated.pdf last seen on 22 May 2023

[26]Kenya: Realising the Right to Information, Article 19 available at https://www.article19.org/data/files/medialibrary/38388/Kenya-RTI-for-web.pdf last seen on 22 May 2023

[27]UNESCO, to recovery and beyond: 2021 UNESCO report on public access to information (SDG 16.10.2),13 (2021) available on https://unesdoc.unesco.org/ark:/48223/pf0000380520 last seen on 22 May 2023

[28]Article 19, Asia Disclosed: A Review of the

Right to Information across Asia (2015) available at https://www.article19.org/data/files/medialibrary/38121/FINAL-Asia-Disclosed-full.pdf last seen on 21 May 2023

[29]Ibid

[30]Ibid

[31]Ibid