Letter from the table: A permit clock should start when the application is received

To the Red Tape Council,

I am writing in reply to Arun in Madurai. I agree with the point in his letter that a business owner needs to know whether a delay is caused by a missing document or simply by a file waiting somewhere. In my case, I could not tell the difference for nearly three weeks.

In March, I took a small premises in Coimbatore. Before opening, I wanted to confirm what approval was needed for the premises and my proposed use. I did not want to assume that a landlord’s earlier use meant I could proceed without checking. The relevant local institution was the Coimbatore City Municipal Corporation. For building permission, the applicable framework includes the Tamil Nadu Combined Development and Building Rules, 2019. I understood that my own query concerned the municipal trade-licence process and the premises particulars; I am not suggesting that every repair or every kind of business requires the same permission.

On 7 April, I went to the Corporation office with my rental agreement, identity documents and the property particulars I had been given. I was directed to submit the application through the available online process. I did that the next morning and saved the acknowledgement. I paid the amount shown on the challan, ₹1,250. I am including that figure because it was part of my outlay, not because I think it is a standard fee for every applicant.

On 14 April, I checked the application status. It did not tell me what remained to be done or when I could expect a decision. I went back with a printed copy. I was asked to provide a clearer copy of a premises document. I submitted it on 16 April and kept the receipt. I could manage that correction, but I had already lost a week because I had not known at the start that the copy might not be accepted.

By 27 April I still had no decision or dated estimate. I went once more to ask whether the file was incomplete. I did not receive a written explanation I could use to plan. I paid ₹28,000 in rent for the month while the premises remained unopened, and spent another ₹1,800 on printing, travel and help preparing papers. I do not blame any individual officer. I do not know where the delay occurred. That is exactly the problem: from the applicant’s side, there was no reliable way to distinguish a pending review from a lost or incomplete file.

What I tried was ordinary: ask before starting, use the prescribed route, provide the documents requested, check the status, and return in person when the status gave no useful answer. Each step took time away from work. A small applicant should not have to make repeated visits just to learn whether the application has reached the right desk.

I support RT-001, the proposed Small Business Impact Standard. For a process like this, the standard should change five practical things:

• One checklist before submission. The applicant should be shown the documents and premises details required for that specific application, with cases of acceptable copies where possible.
• A receipt that starts the clock. It should record the date received, the application reference and the office responsible for the next step.
• A published service time. The applicant should be told how long a complete application normally takes and receive an update if the authority needs more time.
• A single digital status and correction route. If something is missing, the notice should say what it is, where to provide it and whether the review clock pauses until it is supplied.
• A small-business impact check. Before changing a rule or form, the authority should consider the extra cost and time for an applicant who does not have a compliance department.

I also support a deadline for permits, but “silence is consent” needs careful limits. Some permissions protect health, safety, neighbours or public space. Silence should not be treated as approval where the law does not authorize that result. For lower-risk applications, the responsible government should decide in advance which categories

can receive deemed approval, set the legal conditions, and publish how an applicant can rely on it. For all other cases, the authority should at least have to issue a decision or a reasoned delay notice by the published date. A deadline without a consequence or an explanation is just another date on a form.

The Days to Open survey can help make the gap visible. Please count not only the days between filing and approval, but also how many times an applicant must correct, chase or resubmit. Record what the applicant was told at each step. A process that takes ten days with a clear checklist is not the same burden as one that takes ten days after three unexplained visits.