In reality, the proposed recommendations will not create a level
playing field, but obliterate the field altogether.
On July 12, 2020, the Committee of Experts chaired by Kris
Gopalakrishnan published its Report containing recommendations for
creating a regulatory framework governing non-personal data. While
the Report leaves much to be desired, there are four core drawbacks
that hit at its foundation.
1. Lack of empirical evidence on the Indian data
industry and reliance on presumptions
One of the Report's driving force is the need to level the
playing field between the established players and the start-ups in
the Indian data market. Interestingly, the Report's starting
point on this is the unsupported presumption of lack of level
playing field. The Report contains no empirical research on the
current landscape of the data ecosystem in India. Distressingly,
this lack of supporting research and in-depth discussion is not a
solitary occurrence, but a consistent
