 functions. It means having access to government data, information, records, files, documents in any form (Omotayo, 2015). For instance, section 1(1) of the Nigerian Freedom of Information Act 2011 empowers all citizens to access or request both written and unwritten information in the custody or possession of any public official, agency or institution. The Act defines public institution as any legislative, executive, judicial, administrative or advisory body of the Government, including boards, bureau, committees or commissions of the State, and any subsidiary body of those bodies including but not limited to committees and sub-committees which are supported in whole or in part by public fund or which expends public fund and private bodies providing public services, performing public functions or utilizing public funds (s. 31). Information is defined as including "all records, documents and information stored in whatever form, including written, electronic, visual images, sound, audio recording, etc." The inference from these provisions is that it is virtually a no holds bar right of access to information. Omotayo (2015) observes that in some jurisdictions, it may mean not only allowing access to government documents in whatever form they happen to exist, but also opening up the meetings of governments, their advisory bodies and client groups to public scrutiny-the "open government" dimension (Transparency and Accountability Initiative, Opening Government (TAIOG), 2011; Soniyi, 2016). It may include access by individuals to files containing information about themselves and an assurance that the information is not being used for improper or unauthorised purposes.
Indeed, the right to information was as early as 1946 recognised as a fundamental right via Resolution 59(1) adopted during the first session of the United Nations General Assembly (Omotayo, 2015). It is considered as being an essential part of the right to freedom of expression by international human rights tribunals such as the Inter-American and European Courts of Human Rights; and, along with the United Nations, other foremost international authorities such as the Organisation of American States, Organisation for Security and Cooperation in Europe and the African Commission (TAIOG, 2011). For instance, Article 19 of the UDHR states that everyone has the right to freedom of opinion and expression. According to the United Nations, 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 (GAR 217A(III)). This position is reinforced by the proactive Supreme Court of India, which as far back as the early 70s held in Bennett Coleman & Co v The Union of India (1973) that the freedom of speech and expression is inclusive of the right of all citizens to read and be informed. This was later reaffirmed in Manubhai v Life Insurance Corporation AIR (1981) when the court stated that "freedom of speech and expression is that all members should be able to form their beliefs and communicate them freely to others." The utility of the RTI lies in the fact that, among others, it bridges the gap between the government and the people, making the former more responsive to the needs of the latter; and upholds the democratic ideology by promoting openness and transparency in administration, thus reducing corruption (Gopi, 2016). However, the realisation of this goal has a direct bearing on the impor- tance attached to the acquisition of information by both the government and the people. As James Madison aptly observes, "A popular government without popular information, or the means of acquiring it, is but a prologue to a farce or a tragedy or perhaps both. Knowledge will forever govern ignorance, and a people who mean to be their own governors, must arm themselves with the power knowledge gives." (Hunt, 2008)

Institutional Obligations
The FOIA creates for any person a right of access to information, whether or not contained in any written form, which is in the custody or possession of any public official, agency or institution. An applicant need not have any specific interest in the information sought and can apply to court to compel its release (ss.1 & 2(6)) This forestalls the problem of locus standi, which has often hindered the pursuit of certain rights and underscores the fact that the interest or lack of interest of the applicant does not detract from the merit of the request. This is an important principle underlying the FOIA as reiterated by the United States Supreme Court in NARA v Favish (2004) FOIA is often explained as a means for citizens to know "what the Government is up to." This phrase should not be dismissed as a convenient formalism. It defines a structural necessity in a real democracy. The statement confirms that, as a general rule, when documents are within FOIA's disclosure provisions, citizens should not be required to explain why they seek the information. A person requesting the information needs no preconceived idea of the uses the data might serve. The information belongs to citizens to do with as they choose.
It equally reinforces the fundamental nature of this right (Omotayo, 2015). An analogy could be drawn between it and the provision of the Fundamental Rights (Enforcement Procedure) Rules, 2009 on locus standi that the Court shall encourage and welcome public interest litigation in the human rights field and no human rights case may be dismissed or struck out for want of locus standi.
The Rules noted, in particular, that human rights activists, advocates, or groups as well as any nongovernmental organisations, may institute human rights application on behalf of any potential applicant (Para 3(e), Preamble). The Court upheld this principle in Shobayo v C.O.P. [2009][2010] For the sake of emphasis, possession of locus standi has been the bane of the citizens' advocates, in the public interest litigation, to query transparency and accountability in Nigeria. In a democratic dispensation, such as Nigeria's, the citizens have been proclaimed the owners of sovereignty and mandates that place leaders in the saddle. The requirement is a serious fracture of the citizens' inalienable right to ventilate their grievances against poor governance vis a vis expenditure of public funds generated from their taxes. The sacrosanct provisions of section 1(2) of the Freedom of Information Act, 2011, which has ostra-cised this disturbing requirement, has, admirably, remedied the harmful mischief appurtenant to it.
The right of access to information clearly imposes corresponding obligations on public institutions. These obligations include not only the release of record or information in its custody, on request by any person, but also other obligations that are not contingent on request for information such as ensuring that its records are properly organised and maintained, and proactive publication of relevant information (Federal Ministry of Justice, 2013). This segment discusses the requirements of the Act in relation to the obligations of institutions and the challenges associated with these obligations.

Obligation to Keep, Organise and Maintain Record
Under section 2(1) and (2) of the Act, a public institution is obliged to ensure that it records and keeps information about all its activities, operations and businesses; and that it properly organises and maintains all information in its custody in a manner that facilitates public access to such information (s. 9(1) & (2)). Additionally, section 2(5) mandates a public institution to update and review information required to be published under this section periodically, and immediately whenever changes occur. The essence of this is to ensure that relevant pieces of and changes in information are duly brought to the public domain without a prior request for disclosure. The problem, though, is that this provision is awkward and confusing. Are update and review to be done both periodically and immediately whenever changes occur? Or are they both to be done either periodically or immediately whenever changes occur? Or is one to be done periodically and the other immediately whenever changes occur? A review is something that can be done periodically and does not necessarily depend on the occurrence of a change in the system or nature of information whereas an update depends on the occurrence of a change. Surely there is an ambiguity that needs to be resolved here. The provision could be amended either to make both update and review to be undertaken periodically or make update subject to changes while review is undertaken periodically. Also the inclusion of "whenever" after "immediately" is a surplusage that should be dispensed with.
Depending on the intention of the legislature, suggested redrafts could read: 2(5) A public institution shall periodically update and review information required to be published under this section.
Or 2(5) For information required to be published under this section, a public institution shall (a) update the information immediately changes occur; and (b) review the information periodically.  Section 10 criminalises the willful destruction of documents; or doctoring of documents by a public officer in custody of such documents before release to any person, entity or community applying for it. It imposes a minimum punishment of one year imprisonment on conviction by the court for the offence without an option of fine. By virtue of these provisions, public institutions must ensure that adequate measures are put in place to safeguard against records in their possession being tampered with and that such measures are strictly observed (Federal Ministry of Justice, 2013). This is a salient provision, but there could be a problem with its realisation as its practicality is questionable due to the requirement for proof beyond reasonable doubt for criminal offences.
Without a further provision for verification of information and the power to inspect the information received, mere suspicion by an applicant requesting information that such information has been altered, will be insufficient to ground a conviction of the suspected public officer or head of an institution for such offence (Ogbuitepu, 2011). The provision of Schedule 23 of the United Kingdom Freedom of Information Act, 2000, allowing a judge to issue a warrant to the Commissioner to enter and inspect any office of a public authority, which refuses to release