People’s Union for Civil Liberties (PUCL) V. Union of India (UOI) & Ors. (1997)

Case details

Name of the case: People’s Union for Civil Liberties (PUCL) v. Union of India (UOI) and Ors.^[1]

Citation: MANU/SC/0149/1997, AIR 1997 SC 568

Case type: Civil Writ Petition (PIL)

Case number: Writ Petition. (C) No. 256 of 1991

Bench: Division Bench (Honourable Judges of Supreme Court, Justice Kuldip Singh and Justice Saiyed Saghir Ahmad, JJ.)

Name of Appellant: People’s Union for Civil Liberties (PUCL)

Name of Respondent: Union of India and Ors. (assistant director general, department of telecommunication)

Date of Judgement: 18^th December,1996

Name of Court: Honourable Supreme Court of India

Laws Involved: Articles 21, 19(1)(a), 32 and 51 of the Constitution of India; Section 5(2), Section 7 and Section 7(2)(b) of the Indian Telegraph Act, 1885.^[2]

• International Law and Covenants: Article 12 of the Universal Declaration of Human Rights (UDHR) and Article 17 of the International Covenant on Civil and Political Rights (ICCPR).

Introduction

The conflict between state surveillance power and individual liberty lies at the heart of this case. The serious threat posed to individual privacy when authorities abuse sophisticated communication technology was starkly demonstrated by a CBI investigation into unauthorized telephone-tapping of political figures.

The Indian Telegraph Act, 1885 provided the framework, with Section 5(2)^[3] granting the government authority to intercept messages for “public emergency” or “public safety”.^[4] This power, lacking procedural clarity when applied to modern telephone-tapping, fueled massive controversy over fundamental rights violations.

​This was formally challenged in the landmark case of People’s Union for Civil Liberties (PUCL) v. Union of India & Ors. (1997)^[5] in the backdrop of the CBI investigation. The Supreme Court after considering landmark precedents and cited international instruments,^[6] definitively held that phone tapping infringes the fundamental Right to Privacy (Art.21)^{[7] [8]} and Freedom of Speech and Expression (Art. 19(1)(a))^{[9] [10]} granted by the Constitution of India. Finding Section 5(2) procedurally deficient, the Court judicially intervened by issuing nine detailed, mandatory interim guidelines to regulate the Executive’s power and provide the necessary ‘procedure established by law’.^[11]

In an era of rapid technological advancements, the right to engage in private conversations at home or in the workplace has become increasingly vulnerable to exploitation. Safeguarding each citizen’s right to privacy is essential now more than ever, especially from the eyes of government authorities.^[12] 

This commentary will analyse the facts, issues and arguments, examine the Court’s constitutional rationale and critically assess the efficacy of the judicial guidelines framed.

Facts of the case

In the spring of 1990, Chandra Shekhar publicly alleged that the V.P. Singh-led government had been illegally tapping the telephones of 27 politicians, including his own. The allegation led to a nationwide scandal and a subsequent CBI inquiry that revealed the widespread and unauthorised interception of communications by government agencies and MTNL, as reported in “Tapping of politicians phones”, Mainstream, Volume XXIX (March 26, 1991).^{[13] [14] [15]}

Following these revelations, the People’s Union for Civil Liberties (PUCL), an NGO dedicated to human rights and civil liberties, filed a Writ Petition under Art. 32^[16] of the Constitution of India challenging the legality of telephone interception carried out by the Government.

PUCL alleged that interception under Section 5(2) of the Indian Telegraph Act, 1885 was being exercised without adequate authorisation, record-keeping or procedural safeguards and prayed for the provision to be read down to prevent arbitrary surveillance and protect the fundamental rights guaranteed by Articles 21 and 19(1)(a).^[17]

The Union of India defended Section 5(2) as constitutionally valid for cases of public emergency or public safety, emphasised operational secrecy and the practical difficulties of notifying targets and asserted that aggrieved could seek redress from the Government. The Union also admitted that no rules had been framed under Section 7(2)(b)^{[18] [19]} of the Act authorising the central government to prescribe precaution. ^[20]

Various materials including the CBI report and Second Press Commission’s recommendations were placed on record and the petition was taken up for hearing by the Supreme Court.

Issues framed

1. Whether the Section 5(2) of the Indian Telegraph Act,1885, is violative of Right to Privacy guaranteed under Article 21 of Constitution?
2. Whether the Article 19(1)(a) of Indian Constitution is violated by the act of phone tapping, and if so, whether such restriction is saved by Article 19(2)^{[21] [22]} of the Constitution?
3. Whether Section 5(2) of the Indian Telegraph Act, 1885, is both substantively and procedurally constitutional?^[23]

4. Whether there was a need to modify Section 5(2) of the Act to include specific procedures to prevent unfairness and excessive phone tapping?^[24]

Contentions

Petitioner

The People’s Union for Civil Liberties submitted that telephone-tapping constitutes a grave invasion of the fundamental rights guaranteed by Articles 21 and 19(1)(a). Relying on precedents such as Kharak Singh v. State of U.P & Ors. (1963)^[25], Govind v. State of M.P. & Anr. (1975) ^[26] and R. Rajagopal v. State of Tamil Nadu & Ors.(1994),^[27] the counsel, Mr. Rajinder Sachar (Sr. Advocate) argued that the right to privacy is implicit in Art.21 and protects private telephone conversations from arbitrary state intrusion.^[28]

Section 5(2) of the Indian Telegraph Act, 1885, though acknowledged as important for various state purposes, was challenged as procedurally defective on the grounds that while the Act permits interception in specified circumstances, it contains no adequate safeguards and at the relevant time, no rules had been framed under Section 7(2)(b) to prevent misuse.

Therefore, the counsel for PUCL urged the Court that S. 5(2) be read down to require fair, just and reasonable procedure, including mandatory prior judicial sanction (even ex parte in emergencies), specification of targets, written reasons, time-limits and review, failing which interceptions would violate privacy and freedom of speech.^[29]

Respondents

The counsel for Union of India maintained that interception under Section 5(2) of the Indian Telegraph Act is a lawful, necessary measure narrowly confined to situations of public emergency or where public safety is required, specifically for protecting the sovereignty and integrity of India, the security of the State, public order or preventing incitement to offence.

The Union asserted that interceptions are authorized only by duly empowered officers of the Central or State Governments and that the reasons for orders are recorded in writing. However, secrecy is essential because notifying targets would defeat legitimate surveillance.

Where misuse is alleged, the Union pointed to available administrative remedies, namely, representation to the Government and argued that striking down S. 5(2) would unduly handicap the State’s ability to protect national security and public interest.^[30]

Judgement

Ratio Decidendi:

The judgment in the case was delivered by Justice Kuldip Singh on behalf of a two-judge bench, without adissenting opinion.

 I. Telephone tapping violates Art. 21 and Art. 19(1)(a)

The Court placed reliance on the judgments in Kharak Singh vs. State of U.P. & Ors. (1963),^[31] Govind vs. State of M.P. & Anr. (1975)^[32], R. Rajgopal vs. State of Tamil Nadu & Ors. (1994)^[33] and on an international precedent, Wolf v. Colorado (1949)^[34] and noted that though the Indian Constitution did not expressly provide for a right to privacy, the right was a part of the right to “life” and “personal liberty” under Article 21 which could not be curtailed “except according to procedure established by law”. It held that only a case-by-case inquiry would reveal if the right had been infringed or not. 

The Court observed that the right to hold a telephone conversation in the privacy of one’s home or office without interference can certainly be claimed as “right to privacy” since conversations on the telephone, which are an integral part of modern man’s life are often of an intimate and confidential character. Telephone-tapping would, thus, infract Article 21 of the Constitution of India unless it is permitted under the procedure established by law.

The Court also stated that telephone conversations were an exercise of a citizen’s right to freedom of speech and expression under Article 19(1)(a) and hence telephone-tapping unless it comes within the grounds of restrictions under Article 19(2) would infract Article 19(1)(a) of the Constitution.^[35]

International Reference:

The Court, relying on A.D.M. Jabalpur v. Shivkant Shukla (1976)^[36] and Jolly George Varghese & Anr. v. The Bank of Cochin (1980)^[37], noted that India is a party to the International Covenant on Civil and Political Rights (ICCPR) and that Article 17,^{[38] [39]} corresponds to Article 12 of the Universal Declaration of Human Rights (UDHR).^{[40] [41]}Recognising that international law now protects individual rights and that customary rules consistent with domestic law stand incorporated into municipal law, the Court invoked Article 51’s^{[42] [43]}directive to respect international law and concluded that Article 21 must be interpreted in harmony with India’s human-rights obligations.^[44]

 II. Analysis of Section 5(2)

Referring to the observations in Hukam Chand Shyam Lal v. Union of India & Ors. (1975),^[45] the Court analysed Section 5(2) in the following manner:

Section 5(2) permits interception only if a “public emergency”(prevailing of a sudden condition or state of affairs affecting the people at large calling for immediate action) has occurred or the “interest of public safety”(the state or condition of freedom from danger or risk for the people at large) so demands, both objective thresholds that must be apparent to a reasonable person. Consequently, the Government cannot lawfully order telephone-tapping merely because it considers it necessary in the interests of sovereignty and integrity of India etc, unless either of those two preliminary conditions are present.

The first step under Section 5(2) of the Act, therefore, is the occurrence of any public emergency of the existence of a public-safety interest. Thereafter the competent authority under Section 5(2) of the Act is empowered to pass an interception order after recording its reasons in writing that it is necessary or expedient so to do in the interest of either (i) sovereignty and integrity of India, (ii) the security of the State, (iii) friendly relations with foreign States, (iv) public order or (v) for preventing incitement to the commission of an offence.^[46]

The Court, after these considerations, decided not to declare Section 5(2) unconstitutional.^[47]

Further, the Court refused to accept the Mr. Sachar’s submission regarding imposition of prior judicial scrutiny in the Second Press Commission report as the procedural safeguard before passing of interception orders. It reasoned that the power to make rules in this regard rests with the Central Government under Section 7(2)(b)of the Act and censured the government for not framing proper laws despite the severe criticism attracted by Section 5(2).^{[48] [49]}

III. Interim Guidelines laid by the Supreme Court

However, the Court decided to lay down guidelines in the interim period in order to rule out arbitrariness, and to protect the right to privacy since the substantive law as laid down in Section 5(2) of the Act did not prescribe a procedural backing to ensure that the exercise of power is fair and reasonable.

1. Orders may be issued only by the Home Secretary or Home Secretaries of State Governments; in urgent cases the power can be delegated to a Home Department officer not below the rank of Joint Secretary. All orders must be sent to the Review Committee within one week.
2. The order must direct the addressee to intercept communications in the course of their transmission by a public telecommunication system as described in the order, and may also require the addressee to disclose intercepted material to specified persons in the manner set out.
3. Before issuing an order, the authority must consider whether the information could reasonably be obtained by other means.
4. Interception must target communications sent to or from one or more specified addresses, linked to a particular person or particular premises described in the order (i.e., identification of person/address/premises).
5. An order ceases after two months unless renewed; renewals may be made before expiry but the total operating period must not exceed six months.
6. The issuing authority must maintain records of: the intercepted communications, the extent of disclosure and copying of the material (including the identity of recipients) and the number of copies made.
7. Use of intercepted material must be limited to the minimum necessary.
8. Each copy of intercepted material must be destroyed as soon as its retention is no longer necessary.
9. A Review Committee shall, within two months of the interception order, examine whether it was relevant and whether any contravention occurred. If it finds a contravention, it must set aside the order and direct destruction of all intercepted material; if not, it shall record that finding.^[50]

Case analysis:

The verdict led by Justices Kuldip Singh and S. Sagar Ahmad, made this a landmark case and a pioneer in guiding subsequent developments in surveillance laws in India. Though their reasoning was generally correct, there were some grey areas which need to be analyzed and dealt with.

I. The Strengths of the judgement:

• The Court rightly recognized telephone-tapping as a serious intrusion on the Right to Privacy within Art. 21 in the context of modern communication and masterfully linked unauthorized tapping not just to privacy but also to the Freedom of Speech and Expression (Art. 19(1)(a)) as it creates a “chilling effect”, inhibiting free communication.
• The Court by correctly applied the Maneka Gandhi principle and required that any interception must be governed by fair, just and reasonable procedure, rather than left to unguided executive discretion, reframing S. 5(2) from an open license to a conditional power with procedural restraints.
• The Court gave concrete, administrable safeguards which turned abstract constitutional protection into enforceable criteria for review and created judicially reviewable markers to test legality.
• By issuing detailed guidelines, the Court adopted a remedial approach, acting as a temporary “legislator” to prevent the continued and arbitrary violation of fundamental rights in the absence of parliamentary action.

II. The flaws / weaknesses of the judgement:

• The Court chose to not declare S. 5(2) ultra vires but merely read safeguards into it. Critics argue that the underlyingterms, “public safety” and “public emergency” were inherently vague and susceptibleto abuse, requiring the provision itself to be invalidated or reformed by the legislature, not merely fixed by judicial interpretation.
• The judgement’s flaw lay in institutionalizing executive self-review. The Review Committee, being a high-level executive body, provided only internal oversight for interception orders passed by the Home/ Cabinet Secretary (Executive), fundamentally failing to introduce the crucial element of external judicial or legislative scrutiny and leaves a structural accountability gap.^[51]
• The judgement addressed telephone interception in an era before IP/ Internet communications and bulk metadata surveillance; its framework is therefore only partially fit for modern mass surveillance technologies, creating regulatory and doctrinal gaps. Several legal scholars have remarked that the safeguards need statutory modernization to remain meaningful.^[52]
• Though the guidelines mandated destruction of irrelevant material, it offered minimal safeguards regarding the specific collection, storage, use and security of data that was deemed relevant, a gap that proved problematic in the subsequent digital era.

III. Significance of the judgement:

• This was the first judgement to law down a structured, codified mechanism to regulate state surveillance power. Previously, telephone-tapping operated in an administrative grey area with virtually no accountability.
• The case prompted the Central Government to codify guidelines by inserting Rule 419-A, into the Indian Telegraph Rules, 1951,^[53] through the Indian Telegraph (Amendment) Rules, 2007.^[54] Therefore, the judgement had immediate regulatory consequences rather than mere rhetorical value.^[55]
• The PUCL case served as the most essential legal bedrock for the Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India & Ors. (2017)^[56] judgement. It was this case that first established that privacy must be protected against electronic surveillance, making the Puttaswamy declaration of privacy as a fundamental right an evolution, not a revolution.
• The judgement introduced the practical necessity of proportionality (that any state intrusion into fundamental rights must be necessary for a legitimate goal and that means used must be the least intrusive possible), which is now the standard for analyzing state action.

IV. Impacts and Implications of the case:

• The most immediate impact was the administrative formalization of the judicial guidelines, which clarified authorization, duration and nodal officer roles.
• Ministries and telecom operators implemented internal Standard Operating Procedures (SOPs) for target specification, record-keeping and disclosure protocols which would reduce secrecy and prevent casual or politically motivated tapping, thereby opening state surveillance to crucial judicial scrutiny and public challenge.
• The principles are now applied universally to certain modern methods of surveillance, including internet monitoring under the Information Technology Act, 2000.^[57] Legal challenges against digital surveillance rely on PUCL’s insistence on procedural fairness and proportionality.
• Where telephone interception becomes difficult administratively, states and agencies are likely to explore other surveillance forms (metadata collection, internet monitoring, targeted hacking, etc.). The judgement did not comprehensively regulate these newer modalities, producing a shift in surveillance practice.
• The judgement’s focus on targeted interception (specifying the person and number) is a critical weapon against generalized, mass surveillance programs^[58] (e.g., challenges related to the use of Pegasus spyware or large-scale data monitoring), which by its very nature, violates the targeted and reasoned approach mandated by PUCL.
• The biggest ongoing implication is the acknowledgement that the Indian Telegraph Act, 1885, even with PUCL’s recommendations, is obsolete and that there is a need for comprehensive and modern Surveillance law that specifically addresses:
• Data storage and retention policies.
• Oversight by an independent judicial or legislative body.
• Digital communication encryption and metadata access.

Conclusion

PUCL v. Union of India & Ors. remains a cornerstone, justly celebrated for constitutionalizing the right to privacy under Articles 21 and 19(1)(a) against state surveillance. However, its institutional flaw i.e. the reliance on executive self-review for monitoring orders, cannot be ignored. Despite this crucial limitation, the targeted, proportionality-based framework established by PUCL is an indispensable legal tool today. It forms the essential, though imperfect, foundation for challenging digital mass surveillance and demanding comprehensive legal reform in the digital age.

^[1] People’s Union for Civil Liberties (PUCL) v. Union of India (UOI) and Ors., AIR 1997 SC 568.

^[2] Information compiled from Manupatra, MANU/SC/0149/1997.

^[3] The Indian Telegraph Act, 1885 § 5(2), No. 13, Acts of Parliament, 1885 (India).

^[4] Section 5(2) of the Indian Telegraph Act, 1885, states, “On the occurrence of any public emergency, or in the interest of the public safety, the Central Government or a State Government . . . may, if satisfied that it is necessary or expedient so to do in the interests of the sovereignty and integrity of India, the security of the State, friendly relations with foreign States or public order or for preventing incitement to the commission of an offence, for reasons to be recorded in writing, by order, direct that any message or class of messages . . . shall not be transmitted, or shall be intercepted or detained, or shall be disclosed . . . .”

^[5] Id. at 1.

^[6] Privacy Law Library, https://privacylibrary.ccgnlud.org/case/pucl-vs-union-of-india (last visited Nov. 12, 2025).

^[7] INDIA CONST. art. 21.

^[8] Article 21 of the Indian Constitution states, “Protection of life and personal liberty. — No person shall be deprived of his life or personal liberty except according to procedure established by law.”

^[9] INDIA CONST. art. 19, cl.1(a).

^[10] Article 19(1)(a) of the Indian Constitution states, “Protection of certain rights regarding freedom of speech, etc.— (1) (a) All citizens shall have the right to freedom of speech and expression.”

^[11] Id. at 6.

^[12] Eshal Zahur, PEOPLE’S UNION FOR CIVIL LIBERTIES AND ANR. V/S UNION OF INDIA AND ANR., 1996, Legal Vidhiya (Nov. 11, 2025, 9:00 PM), PEOPLE’S UNION FOR CIVIL LIBERTIES AND ANR. V/S UNION OF INDIA AND ANR., 1996 – Legal Vidhiya. 

^[13] Chaitanya Ramachandran, PUCL V. UNION OF INDIA REVISITED: WHY INDIA’S SURVEILLANCE LAW MUST BE REDESIGNED FOR THE DIGITAL AGE, 7 NUJS L.Rev. 105, 105 (2014).

^[14] India Today, https://www.indiatoday.in/magazine/special-report/story/19910228-secret-report-by-cbi-contains-shocking-details-of-phone-tapping-ordered-by-congressi-govts-814118-1991-02-27 (Nov. 12, 2025).

^[15] Id. at 2.

^[16] INDIA CONST. art. 32.

^[17] Akshara Sinha, People’s Union of Civil Liberties (PUCL) v. Union of India, Law essentials Blog (Oct. 25, 2025, 2:24 PM), People’s Union of Civil Liberties (PUCL) v. Union of India.

^[18] The Indian Telegraph Act, 1885 § 7(2)(b), No. 13, Acts of Parliament, 1885 (India).

^[19] Section 7(2)(b) of the Indian Telegraph Act, 1885, states, “Rules under this section may provide for all or any of the following, among other matters, that is to say:— the precautions to be taken for preventing the improper interception or disclosure of messages.”

^[20] Aishwarya Agrawal, PUCL vs Union of India, LawBhoomi (Oct. 24, 2025, 1:45 PM), https://lawbhoomi.com/pucl-vs-union-of-india/.

^[21] INDIA CONST. art. 19, cl.2.

^[22] Article 19(1)(a) of the Indian Constitution states, “Nothing in sub-clause (a) of clause (1) shall affect the operation of any existing law, or prevent the State from making any law, in so far as such law imposes reasonable restrictions . . . in the interests of [the sovereignty and integrity of India, the security of the State, friendly relations with foreign States, public order, decency or morality, or in relation to contempt of court, defamation or incitement to an offence.]”

^[23] Ojaswi Gupta, People’s Union of Civil Liberties (PUCL) v. Union of India, The Legal Lock (Nov. 13, 2025, 5:30 PM), People’s Union of Civil Liberties (PUCL) v. Union of India – The Legal Lock.

^[24] Id. at 17.

^[25] Kharak Singh v. State of U.P. & Ors., AIR 1963 SC 1295, where the Supreme Court held that although the Constitution does not explicitly guarantee a general right to privacy, domiciliary night visits conducted under mere executive orders were unconstitutional as they violated personal liberty under Article 21 and lacked any ‘procedure established by law’.

^[26] Govind v. State of M.P. & Anr., AIR 1975 SC 1378, where the SC developed privacy jurisprudence further, holding that intrusive surveillance measures require statutory backing and that privacy under Article 21 may be curtailed only on compelling state grounds subject to legal safeguards.

^[27] R. Rajagopal v. State of Tamil Nadu & Ors., 1994 SCC (6) 632, where the SC affirmed that the right to privacy is implicit in Article 21, curtailed prior restraints on publication, and balanced freedom of the press with individual privacy by restricting unauthorized disclosure of personal information.

^[28] Id. at 2.

^[29] Id. at 6.

^[30] Id. at 6.

^[31] Id. at 25.

^[32] Id. at 26.

^[33] Id. at 27.

^[34] Wolf v. Colorado, 338 U.S. 25 (1949), where the U.S. Supreme Court held that while the Fourth Amendment’s protection against unreasonable searches and seizures is a fundamental right applicable to the states via the Fourteenth Amendment, the federal exclusionary rule (excluding illegally obtained evidence) is not a necessary component of due process and therefore does not apply to state court proceedings.

^[35] People’s Union for Civil Liberties v. Union of India & Ors., MANU/SC/0149/1997, ¶¶ 13–20 (Dec. 18, 1996).

^[36] A.D.M. Jabalpur v. Shivkant Shukla, AIR 1976 SC 1207, where Justice Khanna in his dissenting opinion observed that while domestic law prevails in case of a conflict with international law, courts should, where the statutory language permits, interpret municipal law in harmony with international law and treaty obligations.

^[37] Jolly George Varghese & Anr. v. The Bank of Cochin, AIR 1980 SC 470, where the SC aligned domestic law (Section 51 CPC) with Article 11 of the International Covenant on Civil and Political Rights (ICCPR), holding that a debtor cannot be imprisoned merely for the inability to fulfil a contractual obligation unless there is proof of wilful refusal or a dishonest intention to avoid payment.

^[38] International Covenant on Civil and Political Rights art. 17, Dec. 16, 1966, 999 U.N.T.S. 171.

^[39] Article 17 of the ICCPR states, “1. No one shall be subjected to arbitrary or unlawful interference with his privacy, family, home or correspondence, nor to unlawful attacks on his honour and reputation. 2. Everyone has the right to the protection of the law against such interference or attacks.”

^[40] Universal Declaration of Human Rights art. 12, G.A. Res. 217 A (III), U.N. Doc. A/810, at 71 (1948).

^[41] Article 12 of the UDHR states, “No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.”

^[42] INDIA CONST. art. 51.

^[43] Article 51 of the Indian Constitution states, “Promotion of international peace and security. — The State shall endeavour to— (a) promote international peace and security; (b) maintain just and honourable relations between nations; (c) foster respect for international law and treaty obligations in the dealings of organised peoples with one another; and (d) encourage settlement of international disputes by arbitration.”

^[44] People’s Union for Civil Liberties v. Union of India & Ors., MANU/SC/0149/1997, ¶¶ 21–25 (Dec. 18, 1996).

^[45] Hukam Chand Shyam Lal v. Union of India & Ors., MANU/SC/0034/1975, where the SC held that statutory powers must be exercised strictly in accordance with prescribed procedures, and any deviation from the mandated procedure renders the action invalid.

^[46] People’s Union for Civil Liberties v. Union of India & Ors., MANU/SC/0149/1997, ¶¶ 26–29 (Dec. 18, 1996).

^[47] Id. at 6.

^[48] People’s Union for Civil Liberties v. Union of India & Ors., MANU/SC/0149/1997, ¶¶ 31–34 (Dec. 18, 1996).

^[49] Id. at 6.

^[50] People’s Union for Civil Liberties v. Union of India & Ors., MANU/SC/0149/1997, ¶¶ 35 (Dec. 18, 1996).

^[51] Id. at 13.

^[52] Id. at 13.

^[53] The Indian Telegraph Rules, 1951, r. 419-A, republished in G.S.R. 933(E), dated Dec. 3, 1990 (India).

^[54] Indian Telegraph (Amendment) Rules, 2007, G.S.R. 193(E), Gazette of India, Pt. II, Sec. 3(i) (Mar. 1, 2007).

^[55] Id. at 13.

^[56] Justice K.S. Puttaswamy (Retd.) & Anr. vs. Union of India & Ors., AIR 2017 SC 4161.

^[57] The Information Technology Act, 2000, No. 21, Acts of Parliament, 2000 (India)

^[58] Id. at 13.