My draft article comparing the UK and India is hereBen Worthy Access to Information in India and the UK 2015.
It examines the impact of two pieces of transparency legislation: the UK Freedom of Information Act 2005 and the Indian Right to Information Act 2005. It looks at the origins and composition of the laws before examining how the two pieces of legislation function. Both laws have led to transparency and accountability by exposure and raising of ‘fire alarms’, with information disclosure used to bring about accountability as well as, to a more limited extent, reform and behaviour change. Of the two laws, the Indian RTI has proved more ‘politicised’ and more capable of initiating political participation. Yet the ‘transformative’ powers of such reforms are limited by poor implementation and resistance. Moreover, the effectiveness of such laws is shaped by context, with India in particular facing deep and complex socio-political obstacles that may prevent the laws having the ‘revolutionary’ effects advocates hoped.
Worthy, Ben, Access to Information in the UK and India (Jan 16, 2014). Available at SSRN: http://ssrn.com/abstract=2579336