Comparative Analysis Of The Key Data Regulations Of India, EU And The US

1. INTRODUCTION

In the past few years, the demand for a robust data protection regime in India has been rife especially in light of the Supreme Court's landmark 2017 ruling in K.S. Puttaswamy v. Union of India¹ ("Puttaswamy") which held that the right to privacy is a fundamental right under Articles 14, 19 and 21 of the Constitution of India. These demands led to the constitution of the Srikrishna Committee which prepared India's first draft legislation in an attempt to lay down a dedicated data protection legislation. The draft has undergone several changes over the years with the latest attempt being – the Digital Personal Data Protection Bill, 2022 ("DPDP"). The Indian government has made some sweeping changes to the earlier iteration of the data protection bill, which had drawn a lot of its inspiration from the European Union's ("EU") General Data Protection Regulation, 2016 ("GDPR")² , often regarded as the benchmark for data privacy by legislators around