1. Introduction.
The data protection regime in India is in a state of flux. The
year of 2017 has been a humdinger of a year for data privacy laws.
On August 24, 2017 the constitutional bench of Supreme
Court1 decided that the right to privacy was, after all,
a fundamental right.2 The Supreme Court also noted in
the matter that "the government has initiated the process
of reviewing the entire area of data protection, it would be
appropriate to leave the matter for expert determination so that a
robust regime for the protection of data is put into place. We
expect that the Union government shall follow up on its decision by
taking all necessary and proper steps." Following the
judgment in re Puttuswamy, the Committee of Experts on a
Data Protection Framework for India chaired by Justice B. N.
Srikrishna released a white paper on November 27, 2017.3
The Ministry of Electronics & Information Technology (MeitY)
issued a press release on December 28, 2017 seeking public
