In the Central Information Commission
at
New Delhi
ORDER
CIC/DS/A/2011/001662
CIC/DS/A/2011/001661
CIC/DS/A/2011/000898
Dates of Hearing: Sep 08, 2011.
Sep 15, 2011
Sep 21, 2011
Date of Decision: Sep 28, 2011
Parties:
Appellant
Shri Rakesh Kumar Gupta
102 SFS Flats DDA,
C & D Block, Shalimar Bagh,
Outer Ring Road
New Delhi – 110 088
The Applicant was present in person
Respondents
1. The Public Information Officer
Life Insurance Corporation Limited
Jeevan Bharati Tower – II,I
124 Connaught Circus
New Delhi
2. The Public Information Officer
Life Insurance Corporation Limited
LIC Building, P.B. No. 2450,
153, Anna Salai,
Chennai – 600 002
3. The Public Information Officer
Life Insurance Corporation Limited
60B, LIC Building,
Hoshangabad Marg,
Bhopal – 462 012
4. The Appellate Authority,
Life Insurance Corporation Limited
Jeevan Bharati Tower – II,I
124 Connaught Circus
New Delhi
5. The Appellate Authority,
Life Insurance Corporation Limited
LIC Building, P.B. No. 2450,
153, Anna Salai,
Chennai – 600 002
6.
The Appellate Authority,
Life Insurance Corporation Limited
60B, LIC Building,
Hoshangabad Marg,
Bhopal – 462 012
Represented by: Shri Niraj Agarwal, RM (CRM) cum CPIO
Smt. Pampa Ghosh, RM (A) New Delhi
Sh. Gagan Dua, AAO (RTI)
Mr. N.P. Sinha Regional Manager cum CPIO Chennai
Smt. Nilanajana Rangarajan
Mr. Sanjeev Kumar, Regional Manager cum CPIO Bhopal
Information Commissioner : Mrs. Annapurna Dixit _______________________________________________________________________
In the Central Information Commission
at
New Delhi
CIC/DS/A/2011/001662
CIC/DS/A/2011/000898
CIC/DS/A/2011/001661
ORDER BACKGROUND File No. : CIC/DS/A/2011/001662 1. The Applicant filed an RTI query dated 16.01.2011 with the Regional Manager (Marketing), Northern Zonal Office, LIC Ltd. seeking detailed information about all the Key man Insurance policies taken in the Northern Zone as also information related to assignment of such policies in favour of key man/other person in a specified excel format in a softcopy in DVD and by email. He further sought inspection of the terms of the policies, the calculation of surrender value and copy of documents upon such inspection. The Applicant further specified that he requires information which dates back to more than 20 years relying on provisions of Section 8 (3) of the RTI Act 2005. The Applicant indicated that he is seeking the information in public interest based on some reference drawn about an Audited Balance Sheet of Escorts Limited for the year 20022003 and alleging that such key man insurance policies led to tax frauds as also siphoning off money by management to the detriment of shareholders. 2. The CPIO by his letter dated 11.02.2011 denied the information under provisions of Section 8 (1) (e) of the RTI Act 2005 stating that the insurance related information relates to contracts between firms/companies and the LIC and hence is fiduciary in nature. Further since the information related to key man insurance policies are not separately maintained nor classified as such and the policies are in fact taken across the entire North Zone in any of the 320 branches resulting in more than 4 crores of insurance policies, collating and collecting such information would result in disproportionate diversion of resources and therefore is exempted from disclosure under Section 7 (9) of the RTI Act 2005. 3. Aggrieved by the denial of information by the CPIO, the Applicant filed his First Appeal which was responded to by the Appellate Authority vide his order dated 02.03.2011 upholding and affirming the CPIO’s order dated 11.02.2011. The AA also added that the information as sought by the Appellant is available in the policy dockets of respective policy numbers and not in any other format. Being spread over among crores of policies, the task of collecting the information which is not specifically classified, would be an impossible task. The Appellantapproached the Central Information Commission with the instant Second Appeal dated 07.03.2011 reiterating all his contentions while placing reliance on the decision of Bhagat Singh on the interpretation of the exemption clauses. However neither the applicability of the aforementioned case nor the allegations of siphoning off money and tax evasion as mentioned above were substantiated since no evidences have been submitted. He further reiterated his contention that as per provisions under Section 8(3) of the RTI Act, he should be allowed access to the information, since some of the information may relate to policies which may have commenced twenty years before the date on which any request is made under Section 6. He further argued that the information should be provided to him since the public interest in disclosure outweighs the harm to the protected interests. 4. The hearing was duly held at the Commission on 08.09.2011 when the parties reiterated their contentions and the Appellant also placed some submissions on record. The Respondent submitted that the entire computerized database containing the information is expansive running into crores of policies which as per the suggestion of the Appellant can be reduced to some lakhs, when searched for the keywords “limited”. The Respondent agreed to the Appellant’s suggestion even to the extent that the above search can be further classified or refined by searching for such specific cases where the “Proposer” of the insurance policy is a distinct and different individual than “Beneficiary/Person Assured”. However, even after this exercise, it was submitted by the Respondent that the resultant data will run into lakhs of policies, which will not comprise the exact information because not all the data will be restricted to only Key man Insurance policies and it would require a thorough physical examination of each of the relevant policy dockets/files to locate the exact information. He further held that information besides being held by the LIC in a fiduciary relationship, is also exempted since it relates to the ‘commercial confidence’ of the “Proposer” the disclosure of which would harm the Company’s competitive position. The Respondent also reiterated his contention of tax evasion and siphoning of funds by the Companies, alleging that the key man insurance policies are generally assigned at the surrender value, which being substantially lower than the fair value of the insurance results in illegal payment to the key man, without informing the shareholders. Moreover, the Appellant alleged that at the point of assignment of the key man insurance policy, no taxes are paid on the difference between surrender value and fair value at the time of assignment, leading to tax evasion. At this juncture, the Appellant stated that he was agreeable to obtain all of this data, which have been sieved to this stage, if the Respondent furnishes the same in the form of a CD. File No. : CIC/DS/A/2011/000898 5. In another similar RTI application filed by the same Applicant on 16.01.2011 before the Regional Manager (Marketing), Southern Zonal Office, LIC Ltd. the Applicant sought similar detailed information about all the Keyman Insurance policies taken in the Southern Zone along with information related to assignment of such policies in favour of key man/other person in the specified excel format in a softcopy in DVD and by email. He further sought inspection of the terms of the policies, the calculation of surrender value and copy of documents upon such inspection. The Applicant specified in this case also, like in the other case mentioned hereinabove that he that has sought information which is older than 20 years and contended that by the operation of the
Section 8 (3), the exemption under Section 8 (1) (b), (d), (e), (f), (g), (h) and (j) of the RTI Act were not applicable for such information. It was contended by the Applicant that he sought the information in public interest based on some reference drawn about an Audited Balance Sheet of Escorts Limited for the year 20022003 and alleging that such key man insurance policies led to tax frauds as also siphoning off money by management to the detriment of the shareholders. 6. The CPIO by his response dated 17.02.2011 denied the information under provisions of Section 8 (1) (e) of the RTI Act 2005 stating that the insurance related information relates to contracts between firms/companies and the LIC and hence is fiduciary in nature. The CPIO added that the key man insurance related information are not separately maintained nor classified as such. The policies are in fact taken across the country in any of the branches, hence collating and collecting such voluminous information would result in disproportionate diversion of resources and therefore information is being denied under Section 7 (9) of the RTI Act 2005. 7. Aggrieved by such denial of information by the CPIO, the Applicant filed a First Appeal which was responded to by the Appellate Authority vide his order dated 04.03.2011 upholding and affirming the CPIO’s order dated 17.02.2011. The AA also added that the information as sought by the Appellant relates to Third party and cannot be parted with unless public interest is involved, which seemed absent in this case. Hence, the Appellant approached the Central Information Commission with the instant Second Appeal dated 11.03.2011 reiterating all his contentions while mentioning the decision of Bhagat Singh passed by the High Court of Delhi, yet again only referring to the interpretation of the exemption clause without establishing the applicability thereof in the instant case. 8. During the hearing held on 15.09.2011 in this case, the Respondent submitted that the information in their computer systems were stored in such a manner that the data can be pulled out using either a “Policy Master” or an “Address Master” search. The “Policy Master” search generates only the name of the person as “Life Assured” not the proposer’s name, in the “Address Master” search the address of the person whose life is assured will bear the same address as that of the proposer company. Moreover, even conducting a search of cases where names of proposer and beneficiary are different will generate even cases of parentchild or spouse forspouse insurance policies. In each case however, the searches will generate enormous results which have to be then physically examined, each policy wise, which is virtually an impossible task. The Respondent while reiterating the arguments for seeking exemption from disclosure of information under Section 8(1) (e) and Section 7(9) of the RTI Act 2005 stated that out of the numerous files, even if one were to sieve out those cases which fall under the category of information which are more than twenty years old, as understood under Section 8 (3), the Appellant in his RTI application itself has clarified that he does not seek information about policies which have already matured. It is also stated that the old records pertaining to more than twenty years back, do not exist in computerized format, since during that period the data storage used to be in physical forms was not
fed into computers, nor do the policies exist in a listed format. There can be indeed no alternative to searching among voluminous policy files, which is a Herculean task in itself and would definitely attract provisions of Section 7(9) of the RTI Act 2005.
9. While elaborating on their contention that the disclosure of information is exempted under Section 8(1)(d) of the RTI Act, the Respondent explained that the keyman being essential for the growth of the company (“Proposer” )any disclosure of the identity of the keyman will only encourage other companies in the market to entice the keyman to join them with promises of better emoluments and increased allowances, thereby affecting the growth of the company. File No. : CIC/DS/A/2011/001661 10. The Applicant filed another RTI query dated 16.01.2011 with the Regional Manager (Marketing), Central Zonal Office, LIC Ltd. seeking the same information as in the above two cases, about all the Key man Insurance policies taken in the Central Zone including information related to assignment of such policies in favour of key man/other person in a specified excel format in a softcopy in DVD and by email. He sought exactly the same information in lines with the aforementioned two cases pertaining to the Central Zone in this case as well as inspection of the terms of the policies, the calculation of surrender value and copy of documents upon such inspection. In this application also he specified that he requires information which dates back to more than 20 years relying on provisions of Section 8 (3) of the RTI Act 2005 while indicating that he sought the information in public interest based on the same example of an Audited Balance Sheet of Escorts Limited for the year 2002 2003 and alleging that such key man insurance policies led to tax frauds and siphoning off money by management to the detriment of shareholders. 11. The CPIO by his letter dated 07.02.2011 denied the information on the ground that the required information was not readily available in any format/register with them. The CPIO further submitted that the insurance is given under Conventional Policy Portfolio which reflected 90 lakhs policies in force as on 31.03.2010. Moreover it has been clearly submitted that the policyholder database does not have any provision of identification for Key man policies since no separate labeling is done for the key man policies. Hence, as in the aforementioned cases, collating and collecting such information would require physical verification of records which would result in disproportionate diversion of resources and therefore is exempted from disclosure under Section 7 (9) of the RTI Act 2005. The CPIO also sought exemption from disclosure of information invoking Section 8(1) (e) of the RTI Act 2005 stating that he held a fiduciary relationship with their policyholders. 12. Aggrieved by the denial of information by the CPIO, the Applicant filed his First Appeal dated 04.02.2011 contending that the CPIO had wrongly applied the provisions of exemption under Section 8(1)(e) and 7(9) of the
RTI Act 2005. The Appellate Authority responded vide his order dated 03.03.2011 upholding and affirming the CPIO’s order dated 07.02.2011 invoking provisions of the Section 8 (1) (e), (j) and Section 7 (9) of the RTI Act 2005. Being denied the information repeatedly, the Appellant approached the Central Information Commission with the instant Second Appeal dated 08.03.2011 reiterating all his contentions. He once again placed reliance on the decision of Bhagat Singh quoting as follows:
“……As is reflected in its preambular paragraphs, the enactment seeks to promote transparency, arrest corruption and to hold the Government and its instrumentalities accountable to the governed. This spirit of the Act must be borne in mind while construing the provisions contained therein. 13. Access to information, under Section 3 of the Act, is the rule and exemptions under Section 8, the exception. Section 8 being a restriction on this fundamental right, must therefore is to be strictly construed. It should not be interpreted in manner as to shadow the very right itself….” He further stressed that the Act being a rights based enactment should be liberally interpreted quoting from the aforementioned decision as follows: “…… 14. A rights based enactment is akin to a welfare measure, like the Act, should receive a liberal interpretation. The contextual background and history of the Act is such that the exemptions, outlined in Section 8, relieving the authorities from the obligation to provide information, constitute restrictions on the exercise of the rights provided by it. Therefore, such exemption provisions have to be construed in their terms; …………. Adopting a different approach would result in narrowing the rights and approving a judicially mandated class of restriction on the rights under the Act, which is unwarranted….” 13. The applicability of the aforementioned decision has not been established in the submission, except that it discusses the celebrated legal position of the case, which is nevertheless distinct and therefore distinguishable in this case. Even the allegations of siphoning off money and tax evasion as mentioned above have not been substantiated in the submissions neither have any evidences to this effect been submitted. The Appellant further reiterated his contention that as per provisions under Section 8(3) of the RTI Act, he should be allowed access to the information, since some of the information may relate to policies which may have commenced twenty years before the date on which any request is made under Section 6. He further argued that the information should be provided to him since the public interest in disclosure outweighs the harm to the protected interests.
14. The hearing was duly held at the Commission on 21.09.2011 during which the parties reiterated their contentions and the Appellant also placed some submissions on record. The Respondent reiterated his contentions as made hereinabove seeking exemptions from disclosure of information as stated hereinabove. Apart from the fact that the information was not available in the same format as the same had been sought, it was also submitted by the Respondent that the exact information could not be located without actual physical verification of the extensive records. He further stated that the Respondent held the information belonging to the Third Party viz. the companies/organizations, since LIC stood in fiduciary relationship with the
companies/organizations. Thus the information was debarred from disclosure on both counts of belonging to the Third Party as also because the information was held in fiduciary capacity. DECISION
15.
The Appellant argued during the three hearings that were held, that key man insurance is commercial information of the entity which has taken the policy. Most of the information sought is generated by the Public Authority like the policy number, date of maturity, table number, brief terms of policy, surrender value at the time of assignment, premium paid upto assignment amount paid at the time of maturity , expiry of period, number and date of payment, new policy number etc. and are therefore public information which cannot be called confidential information that has been supplied to the LIC , which also according to the Appellant cannot be considered as being held by LIC in a fiduciary capacity. 16. The Commission, in order to get a clearer picture of Key man Insurance policies, explored the meaning of the term and noted the following: Key man (Key person) Insurance Policy The Keyman Insurance policy is an important form of business insurance. There is no legal definition for "key person insurance". In general, it can be described as an insurance policy taken out by a business company to compensate that business for financial losses that would arise from the death or extended incapacity of the member of the business specified on the policy. The policy’s term does not extend beyond the period of the key person’s usefulness to the business. The aim is to compensate the business for losses and facilitate business continuity. Key person insurance does not indemnify the actual losses incurred but compensates with a fixed monetary sum as specified on the insurance policy.An employer may take out a key person insurance policy on the life or health of any employee whose knowledge, work, or overall contribution is considered uniquely valuable to the company. The employer does this to offset the costs (such as hiring temporary help or recruiting a successor) and losses (such as a decreased ability to transact business until successors are trained) which the employer is likely to suffer in the event of the loss of a key person. Who can be a Key man? Anybody with specialized skills, whose loss can cause a financial strain to the company are eligible for Key man Insurance. For example, they could be: 1. Directors of a Company 2. Key Sales People 3. Key Project Managers
4.
People with specific skills. 17. The position that clearly emerges from the above definition, and also from the submissions by the Respondents in all the three cases, both on record and oral during the hearings is that the Key man insurance is a lifeinsurance policy taken on the life of a special person in the organization with a view to providing liquidity, financial strength and security to the business organization in case of losses due to death, absence or exit otherwise of the key man from the business. The company’s progress and profits therefore apparently depend upon the vital decisions made by the key man, based on his knowledge, analytical powers and skills which are crucial traits that are required in this competitive marketing environment and are possessed by special individuals such as the key man,.
18. If this is so, the Commission believes that it is imperative that all efforts are made by the Companies/Organizations to ensure that the key intellectual capabilities, technical expertise, skills, knowledge and the entrepreneurial vision of the key man are retained by them. (This argument was also put forth before
the Commission by Respondents during the hearings). It is evident that to retain the key man, the
Companies/Organization must assiduously prevent any disclosure of details about such employees lest it will allow the competitors in the market to allure these individuals with better job prospects and incentives to impair the original company’s ability to maintain its market dominance. The Commission therefore holds that by no stretch of imagination can this “commercially confident” information sought about key man policies by the Appellant, be considered as disclosable by LIC (Public Authority) under Section 8(1)(d) of the RTI Act, although LIC (a Public Authority) is holding this ‘commercially confident information ’.
19.
That the information is also available with the Life Insurance Company in a fiduciary capacity and therefore is exempt from disclosure under Section 8(1)(e) of the RTI Act is undisputable. The Supreme Court in the case of Central Board of Secondary Education & Anr.v. Aditya Bandopadhyaya & Ors has, after examining the scope of the meaning of the word ‘fiduciary relationship’ observed as follows: “But the words ‘information available to a person in his fiduciary relationship’ are used in Section 8(1)e) of the RTI Act in its normal and well recognized sense, that is to refer to persons who act in a fiduciary capacity, with reference to a specific beneficiary or beneficiaries who are expected to be protected or benefited by the actions of the fiduciary – a trustee with reference to the beneficiary of the trust, a guardian with reference to a minor/physically infirm/mentally challenged, a parent with reference to a child , a lawyer or a chartered accountant with reference to a client, a doctor or nurse with reference to a patient, an agent with reference to a principal, a partner with reference to another partner, a Director of a company with reference to a shareholder, an executor with reference to a legatee, a receiver with reference to the parties to a list, an employer with reference to the confidential information relating to the employee and an employee with reference to business dealings/transaction of the employer” The upshot of the Supreme Court’s observation as given hereinabove is that in the instant case the relationship between LIC and the companies /organizations is held to be fiduciary in nature since the beneficiaries (Companies/Organizations) have trusted the Life Insurance Company to protect the ‘commercially confident’information being held (LIC) by it from becoming available in the public domain. It is therefore held by the Commission that information sought by the Appellant from the LIC is exempt from disclosure under Section 8(1) (e) of the RTI Act. 20. The Appellant in his contentions has further stressed that the exercise of Section 8 (3) negates the function of Section 8 (1) (e) of the RTI Act 2005 and therefore, the exemption of fiduciary relations cannot be sought by the Respondent to deny information which is more than 20 years old. At this, the Respondents contended that while they deny the information about “live” key man insurance policies on grounds of confidentiality, they would have no objection to supplying information related to policies which had matured 20 years ago, provided the records still exist and are traceable from the crores of old records available with them and also since such records are cleared off every ten years upon maturity of insurance policies, as a matter of organizational policy and practice. They also explained that information about policies which had matured twenty years ago, if indeed they still exist, has to be compiled manually from crores of records as the records were not computerized twenty years ago. The likelihood of tracing physical information about Key man insurance policies which have matured twenty years ago, therefore, according to the Respondents, is almost impossible. In any event, it was noted by the Commission that the Appellant is not seeking any information about policies which have matured twenty years ago and that the information he is seeking pertains to ‘live’ policies which have not yet matured. As explained in the preceding para hereinabove, the disclosure of ‘live’ key man policies is indeed exempted u/s 8(1) (d) and 8(1)(e) of the RTI Act.
21.
Furthermore, The Appellant has argued while invoking Section 8(2) of the RTI Act that in the instant case the LIC should allow him access to information since the public interest in disclosure outweighs the harm to protected interest. While elaborating the public interest aspect, the Appellant has alleged that Companies such as Escorts Limited have been taking key man insurance policies on the lives of key men some of which have been assigned to the Executives and Managing Directors, the consideration of such assignment being the guaranteed surrender value as certified by LIC. He has alleged that after three or four years of paying the major premium on key man insurance, the companies have been assigning the policies to the Executives. According to the Appellant, after a gap of time, a new policy is obtained for the same key man, resulting in payments of more money than that permissible under the IT Act, to certain key influential persons. The objective of transfer of policies after some time as alleged by the Appellant, is mainly to siphon funds from the Company without bothering to obtain the permission of shareholders as well as Government and to evade payment of taxes.22.
While examining the aspect of public interest which has been repeatedly pointed out by the Appellant, it is necessary to validate his allegations first. It is noted that the Appellant while alleging tax evasion and siphoning of funds, has stated that the key man insurance policies are generally assigned at the surrender value which is a distress value and arrived at after deducting expenses of future period also. Being at substantially lower prices than the fair market value of the insurance, the Appellant alleges that such assignment results in illegal payment to the key man, without informing theminority shareholders. Moreover, the Appellant has alleged that at the point of assignment of the key man insurance policy, no taxes are paid on the difference between surrender value and fair value which tantamounts to tax evasion. The Appellant argued that surrender value of the policy is nothing but the distressed value of the policy whereas the actual value of the income is the market value of the assets transferred. He contended that surrender value on the average works out to be only around 25% of the fair value which as understood by the Commission is an estimate of a security's worth in the open market where calculations typically take into account future growth rates, profit margins, and risk factors, among other items. It is the case of the Appellant that since the tax payment is on the surrender value, therefore, the rate of tax paid is also substantially lower than the actual tax payable.
23.
The Commission, however, is of the view that the Appellant’s arguments are vague in as much as they are nowhere substantiated with either particulars about the culprit in whose hands such evasion or siphoning of funds is taking place or even any data to prove such economic offences. All of the allegations with neither names of the wrongdoer nor the figurative data to support such allegations, except some brief data in the case of one company Escorts Limited cannot be considered to be reason enough to disclose data which is ‘commercially confidential’ and being held in a fiduciary relationship by the LIC. Thus the case of public interest as made out by the Appellant is not convincing enough and hence in the absence of incriminating evidence accompanying the statements indicating any compromise to public interest, the Commission denies the disclosure of information sought u/s 8(1)(d) and 8(1)(e). 24. The Commission also in support of its contention that information need not be disclosed since the “public interest” involved in disclosure of information has not been convincingly established, would like to quote at this stage from the “Freedom of Information Act (UK) Awareness Guidance, Nos 5 and 2 ”, which while discussing the aspects of “commercial confidentiality” and “public interest” have stated as follows: ………“ there is no requirement for an exceptional case to be made in order for the duty of confidence to be overridden on public interest grounds . In other words , there has to be a straightforward balancing of the competing public interest arguments . Unlike the public interest test for the qualified exemptions , where the balance favours the disclosure of information, the burden of proof(in the case of commercial confidence) is reversed in that the information should be withheld unless the public interest in disclosure outweighs the public interest in maintaining the confidence.” ………. “in balancing confidentiality against the public interest, the task is not to weigh the impact upon the individual against the good of society, but rather the good of society against the importance of preserving confidences”. With reference to the above quotes, there is no doubt in the mind of the undersigned (Commissioner) that the Appellant is desperately makng out an exceptional case for disclosure of information about key man insuranceof a large number of Companies and Organizations without giving any strong grounds for breaching the confidentiality and without any convincing arguments as to why the public interest in discloure of
information outweighs the public interest in maintaining the confidence. 25. In the given circumstances, the Commission decides that the Respondent from Chennai, as agreed to during the hearing, and as requested by the Appellant, should submit a duly notarized affidavit on a Non Judicial Stamp paper containing the format being used for the computer generated information as available on the official website of the Respondent/s, including details (headings of columns only) of the various fields of search based on which various information can be populated like the Policy Master and the Address Master etc. as discussed during the hearing. Affidavit to be provided by 22.10.11. 26. As far as the information is concerned, the same is denied u/s 8(1)(d) and 8(1) (e) of the RTI Act, as explained in the preceding paragraphs . 27. The appeals are disposed off with the above directions. (Annapurna Dixit) Information Commissioner Authenticated true copy: (G. Subramanian) Deputy Registrar Announced in open Court on 28.09.11 Cc: 1. Shri Rakesh Kumar Gupta 102 SFS Flats DDA, C & D Block, Shalimar Bagh, Outer Ring Road New Delhi – 110 088 2. The Public Information Officer Life Insurance Corporation Limited Jeevan Bharati Tower – II,I 124 Connaught Circus New Delhi
3. The Public Information Officer Life Insurance Corporation Limited LIC Building, P.B. No. 2450, 153, Anna Salai, Chennai – 600 002 4. The Public Information Officer Life Insurance Corporation Limited 60B, LIC Building, Hoshangabad Marg, Bhopal – 462 012 5. The Appellate Authority, Life Insurance Corporation Limited Jeevan Bharati Tower – II,I 124 Connaught Circus New Delhi 6. The Appellate Authority, Life Insurance Corporation Limited LIC Building, P.B. No. 2450, 153, Anna Salai, Chennai – 600 002 7. The Appellate Authority, Life Insurance Corporation Limited 60B, LIC Building, Hoshangabad Marg, Bhopal – 462 012 8. Officer in charge, NIC
