Crime against women in cyber world

Prof. Jay S. Bhongale^*

Abstract

Information technology is like two side edge of human development, progress and profit as well as humiliation, suppression and subjugation especially in related to women it get more spiky and spiny. The cyber world is a virtual reality where everyone conceals their own identity. There are several crimes known and an unknown to normal person who is mostly women get victimized. Several criminal like hackers, crackers, and stalkers have institute methods and measures to hamper with internet accounts got access to user’s computer system may stole the important data of the user. If user is women then crimes like harassment through mail, cyber stalking, cyber sex, cyber defamation, photo morphing, non-consensual pornography, child pornography, cyber bullying, cyber grooming, publishing obscene material in electronic form etc.

Present article will highlight especially about the nature and category of cyber crimes which may take place against women while using internet. The most important is the kind of measures and technique, skills used by the criminals through which victim may easily trap. It also will discuss about procedure for remedy to the women when they trapped under these kind cybercrime and legal provision and procedural aspect to get redress of this kind of situation. It is very indispensable that what kind key measures will be functional for online safety while using the internet.

Keywords: cyber world, cyber crime, victimization, remedy, online safety

INTRODUCTION

The information in the public domain is like toothpaste, once it is out of the tube one can’t get it back in and once the information is in the public domain it will never go away.¹

There is large amount of cyber crimes raise against women especially during lockdown. There are several people behind internet who try to harass women by sending email, stalking by only using chat rooms, websites like facebook, twitter, instagram. Cyber-crimes against women include cyber stalking, cyber pornography, circulating images, video clips of women engaged in intimate acts, morphing, sending obscene, defamatory, annoying messages, online trolling, bullying, blackmailing, threat or intimidation, and email spoofing and impersonation.² This list is not exclusive it is inclusive, because on online platform cyber hacking is getting more and more professional and developed, these people always find some different sharp toll for harass the victim and exploit them.

“Violence against women” is defined by the Council of Europe as ‘a violation of human rights and a form of discrimination against women and shall mean all acts of gender-based violence that result in, or are likely to result in, physical, sexual, psychological or economic harm or suffering to women, including threats of such acts, coercion or arbitrary deprivation of liberty, whether occurring in public or in private life”.³ Even though the definition is so broad to include every aspect crime against woman but crime against woman in cyber world is different than crime against women. Actually it is very complicated crimes against women where wrongdoer identity and his domain are not specific and clear. Most of the time, organized crimes have committed under the veil of cyber world so then finding offender becomes more difficult than punishing them.

^* Assistant professor,Bharati vidyapeeth Deemed University, New Law College, Pune

¹ Subhranshu Rout v. State of Odisha decided BLAPL No. 4592 of 2020 Decided On: 23.11.2020 in Odisha High Court; MANU/OR/0270/2020

² Ms. Saumya Uma, Outlawing Cyber Crimes Against Women In India, Bharati Law Review, April – June, 2017, www.manupatra.com

³(https://rm.coe.int/ CoERMPublicCommonSearchServices/DisplayDCTMContent? documentId=090000168008482e) last visited 20^th January, 2020.

Crime against women in cyber world also treated as violation of dignity and privacy of woman. The most popular meaning of “right to privacy” is–“the right to be let alone”.⁴ The European Union Regulation of 2016⁵ has recognized what has been termed as “the right to be forgotten”. This does not mean that all aspects of earlier existence are to be obliterate, as some may have a social ramification. If we were to recognise a similar right, it would only mean that an individual, who is no longer desirous of his personal data to be processed or stored, should be able to remove it from the system where the personal data/information is no longer necessary, relevant, or is incorrect and serves no legitimate interest. Such a right cannot be exercised where the information/data is necessary, for exercising the right of freedom of expression and information, for compliance with legal obligations, for the performance of a task carried out in public interest, on the grounds of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defence of legal claims. Such justifications would be valid in all cases of breach of privacy, including breaches of data privacy.”

CYBER-CRIMES AGAINST WOMEN IN INDIA

According to the official statistics provided by the National Crime Records Bureau, Government of India, 9622 cases of cyber-crimes were registered in 2014 and 5752 persons arrested. In 2015, 11,592 cases were registered – an increase of 20% in registration of cases from the previous year – and 8121 persons arrested.⁶

The number of social network users in India has increased drastically from 181.7 million in 2015 to 216.5 million in 2016 to a projected 250.8 million in 2017.⁷ It increase more than 336.7 million in 2020. A study of internet users in India, conducted by the Boston Consulting Group and Retailers Association of India, states that approximately 29% of the users in India are women, while the remaining 71% are men.⁸ NCRB data in 2018 discovered 6030 cyber crimes were recorded by women. In 2020 there were 412 cyber compliant was registered from March to April.

CYBER STALKING

Cyber stalking is sending email, text messages or to follow in internet, it may not sexual or physical in nature still it may harass, pursue, torture to the victim. It is interfere into an individual privacy. In this crime offender try to establish a relationship (online or actual) without her consent. Sending email, text messages which are nasty, disgustful due to victim caught in distress or in fear. Posting provoked, offensive comments, sharing intimate photos or video of victim through mobile phone or internet. Follow silently and tracking a woman’s, online and offline activities and movements of woman. All information of women gather through internet that also without her knowledge like what is her interest, likes dislikes, friends and family, relationship, home address, contact detail, daily routine etc.

LAW

⁴ Gobind v. State of M.P., (1975) 2 SCC 148

⁵ [Regulation No. (EU) 2016/679 of the European Parliament and of the Council of 27-4-2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive No. 95/46/EC (General Data Protection Regulation).].

⁶ Sydney Anderson, India’s Gender Digital Divide: Women and Politics in Twitter, OBSERVER RESEARCH FOUNDATION  ISSUE  BRIEF,  October  2015,  Issue  No.  108,  (10  January,  2020,  11.00  AM),

http://www.orfonline.org/wpcontent/uploads/2015/12/ORFIssueBrief_108.pdf.

⁷  Number  of  Social  Network  Users  in  India  from  2015  to  2021  (March  15,  2017,  11.04  AM), https://www.statista.com/statistics/278407/number-of-socialnetwork- users-in-India/. Last visited January 20, 2020.

⁸ Boston Consulting Group & Retailers Association of India (2016), Decoding Digital @ Retail: Winning the Omnichannel Consumer (14 January , 2020, 11.00 AM),

http://image-src.bcg.com/BCG_COM/Decoding-Digital-Retail-Feb-2016-  India_tcm21-28732.pdf.

Section 354 D of IPC and S. 66E of the Information Technology Act, 2008

Section 354 D of IPC Speaks Any man who follows a woman and contacts or attempts to contact her for personal interaction repeatedly despite a clear disinterest from such woman, would be accused of the offence of stalking. When he monitors the use of internet, email or any other form of electronic communication by the woman, after hacking/cracking her password/committing theft of her identity, such an act would amount to cyber stalking.

PUNISHMENT: imprisonment up to 3 years and fine for first conviction. Section 66 E of IT, Act, [Punishment for violation of privacy]

Whoever, intentionally or knowingly captures, publishes or transmits the image of a private area of any person without his or her consent, under circumstances violating the privacy of that person

PUNISHMENT: Imprisonment up to 3 years or fine not exceeding 2 lakh rupees. CASE LAW:

Yogesh Prabhu v. State of Maharashtra⁹

In 2009 with formal familiar with accused on internet victim chatted with him on online, he made marriage proposal, rejected by her, she stopped online conversation. Still he followed her on internet, stalked her. Some times after she received mail from unknown account containing obscene picture and video clips, she ignore the mail, but it continued, she file complaint finally, Cyber Crime Investigation Cell continued investigation, Magistrate court convicted under S. 509 IPC (words, gestures or acts intended to insult the modesty of a woman) and S. 66E of the Information Technology Act, 2008 (punishment for violation of privacy). This case is responsible to amend IPC S. 354 D of the IPC.

RECENT CASE LAW:

Jibin Babu v. State of Kerala¹⁰,

Victim mentioned in statement that she was in love with accused for few years, they used to meet when accused come to India because accused was in Gulf, accused came in February 2019, accused took her to a hotel and they had sex in hotel, the accused had taken her obscene picture and circulated the same among the their friends. Case was registered under section 66 E, 67 and 67 A of Information Technology Act.

Sazzadur Rahman v. The State of Assam and Ors.¹¹

The accused create fake facebook account of victim, accused mentioned name, upload obscene picture and some insulting language against victim. Trial court convicted accused under sections 354 D of IPC and 66 E of IT Act. Trial court rejected the application of accused which was file under 311 of CRPC. Thereafter under section 482 of CRPC was filed, Gauhati High Court dismissed the application.

NON-CONSENSUAL PORNOGRAPHY

It means without consent of victim online circulation of sexual graphic or lascivious photographs or videos. It may also call as Acts of voyeurism. The offender most of the time ex-partner of the victim who obtain photograph and indecent videos of the victim and it may posted on online platform or online posted on porn cites. This is also being called as ‘revenge porn’. The purpose of this crime may be to humiliate or disgrace the victim publicly. However it is not necessary that offender would from familiar relationship or ex-partner of the victim and motive may not be always revenge from the

⁹ 2006(3) MhLj 691, see also Prasanto K Roy, ‘Why online harassment goes unpunished in India’, (13 January,2020, 4.30

PM), http://www.bbc.com/news/world-asia-india- 33532706.

¹⁰ Decided by Kerala High Court on 26 August, 2020.

¹¹ Criminal Petition No. 654 2019.

victim. Sometimes it may have commercial or business purpose to post intimate photographs or videos of victim. There are several no. of websites available on internet where users can post images and videos along with personal information such as victim address and personal contact number.

LAW

1. Section 292 of IPC: Distribution or circulation of obscene material
2. Section 354of IPC: Voyeurism
   1. Watching or capturing the image of a woman or disseminating such image;
   1. The image is of a woman engaging in a private act in circumstances where she would not usually have the expectation of being observed by the perpetrator or others;
   1. Private act includes
      1. Act of watching carried out in a place that would reasonably be expected to provide privacy to the woman and
      1. Where the victim’s genitals, posterior or breasts are exposed or covered only in underwear; or
      1. The victim is using a lavatory; or
      1. The victim doing a sexual act that is not ordinarily done in public.

The offence of voyeurism in the IPC is punishable with 1-3 years of imprisonment and fine for the first conviction, and 3-7 years of imprisonment and fine for subsequent convictions.

• Section 499: Act done by a person intending to harm individual’s reputation or character.
• Section 509 of IPC: act intended to insult the modesty of a woman.

1. S. 66E of the IT Act –

which makes violation of privacy by capturing, publishing or transmitting the image of a private area of any person without his or her consent, a punishable offence Cyber pornography is the act of using the cyber space to create, publish or disseminate pornographic materials.

• S. 67: publishing or transmitting of material containing sexually explicit act, etc in electronic form.
• S. 72 Breach of confidentiality and privacy

CASE LAWS:

Avnish bajaj v. State¹², in this case Delhi public School students sexual acts was shoot on mobile and MMS created which was illegally distributed on the internet as well as bid to auction on eBay India website. The Chief executive officer of the website who was responsible brings to the court but trial was conducted under provision of IT Act, because IPC did not criminalize such acts.

Sazzadur Rahman v. The State of Assam and Ors¹³

The accused create fake facebook account of victim, accused mentioned name, upload obscene picture and some insulting language against victim. Trial court convicted accused under sections 354 D of IPC and 66 E of IT Act. Trial court

¹² Avnish bajaj v. State, (2008) 150 DLT 769; See also State of West Bengal v. Animesh Boxi, C.R.M. No. 11806 of 2017.

¹³ Criminal Petition No. 654 2019.

rejected the application of accused which was file under 311 of CRPC. Thereafter under section 482 of CRPC was filed, Gauhati High Court dismissed the application.

State of West Bengal v. Animesh Boxi¹⁴

In this case accused had intimate relationship with the victim; he achieved the intimate picture and videos of victim in the guise of promise of marriage, uploaded on porn site and website without consent of victim with name of the victim and victim father names. Court sentenced accused to five years imprisonment and 9000 fine.

LLM Student at Swami Shukdevanand Law College v. State of Uttar Pradesh¹⁵

Miss “A” after finishing her 5 years LLB course in SS Law College, Shahjahanpur, desired to take admission in LLM and in that connection she met the Principal of SS Law College, Shahjahanpur. The Principal took Miss “A” to the accused Chinmayanand who was the President of the Managing Committee of the College. It is stated that the accused is the Karta

– Dharta of the entire ashram campus and all the five institutions are in the same campus. When she was taking her bath in hostel bathroom, the accused got it video recorded and thereafter her sexual exploitation began. She was not only raped but sexually exploited for over a year till she managed to escape. It is also stated that the victim was forced to massage the accused in a nude condition on a daily basis. It is stated that she was sexually exploited under threat that her family would have to face dire consequences as also that her bathing and rape videos would be made viral. It is stated that after several months, the victim mustered courage to expose the highly positioned accused and for that end she bought a device to prepare videos of incidents when she was forced to massage the accused. It is stated that the victim took help of one college mate, who was her family friend, and with his help she could manage to escape from the clutches of the accused with an idea of making a police complaint.

MORPHING

In this case defaulter may download the victim picture or videos from social websites or hacking from personal account of victim, edited the picture again reposted or uploads on different websites by creating fake profile account after editing them. Most of the time an image of the women may be targeted, and woman face may attached to the naked or skimpily clad body of porn star or another via using image editing software.

Most of the time celebrity or heroines and model are the soft target of these perpetrator b t sometimes normal women also being targeted the purpose of this may be to humiliate particular woman or disrespect in the society, malign her character etc.

LAW:

• Under IPC sexual harassment under S. 354A, public nuisance under S. 290, obscenity under S. 292A and S. 501 for defamation
• S.43 IT Act(which includes acts of unauthorized downloading/copying/extracting and destroying/altering data)
• S. 66 of the IT Act: computer associated offences

CASE LAW:

State v. Madachirayil gopinathan suni¹⁶

¹⁴ State of West Bengal v. Animesh Boxi, C.R.M. No. 11806 of 2017.

¹⁵ Allahabad High Court, Criminal Misc. Writ Petition No. 21181 of 2019, decided on 30^th April 2020.

¹⁶ Chief Metropolitan Magistrate, Tis Hajari Court, Delhi decided on 31 august, 2018; see a Sasikala Pushpa v. Facebook India and ors decided by Delhi High Court June 2, 2020.

Accused sent obscene and threatening mails to the complainant, from him emails IDS, with morphed/indecent photographs of the complainant, accused already had some photographs of the complainant, he morphed these photographs, accused try to sought sexual favours from the complainant and threatened her that her photograph will send to her husband, after refusal he uploaded these photographs on the India times club site, with intension insult to modesty of complainant. Court upheld offences, accused held guilty under 67 of IT Act, as well as offence under section 506,507 and 509 of IPC make out.

SENDING OBSCENE, DEFAMATORY, INSULTING MESSAGES

This is offence related to posting a woman photograph or mobile number or any other contact details on pornographic site, to show that she is involve in sex worker business. This is the violation of privacy of the woman as her personal information posted on public. Sending obscene and annoying messages through WhatsApp, electronic mail, Instant Messenger and other such modes, are other forms of cyber-crimes against women.¹⁷

LAW:

• sexual harassment (S. 354A IPC),
• defamation (S. 499IPC),
• assault or criminal force to woman with intent to outrage her modesty (S. 354 IPC)
• Word, gesture or act intended to insult the modesty of a woman (S.509 IPC).
• Section 469 of IPC : forgery for purpose of harming reputation
• Section 67 of IT Act: publication of submit an electronic mode that is against the will and is to cause defamation. CASE LAW:

SuhasKatti v. State of Tamil Nadu¹⁸

The case is about the posting offensive and indecent massages on internet regarding victim who was chief judicial metropolitan magistrate. The fact of this case is that accused desired to marry victim but she married someone else, after her divorced try to persuade her, the woman rejected him, not being to accept the rejection accused started harassing her by sharing her number and obscene messages on different group that she is in business of sex. As a result the victim started receiving calls by people, victim filed complaint under section 67 of IT Act, 2000 also under 469, 509 of IPC. The accused was held guilty and punished by the court under above provisions of law.

ONLINE TROLLING, BULLYING

Bulying is the aggressive behaviour through use of superior strength or dominant position; cyber bullying refers to the same act through the electronic medium.

It is the “wilful and repeated harm inflictedthrough the use of computers, cell phones or other electronic devices, bysending messages of an intimidating or threatening nature. Since the electronic medium lends the power and strength of anonymity and limitless reach across the world, even a person who may be bullied in real life becomes the bully online despite the lack of superior physical strength or dominant position in society”¹⁹

CASE LAW:

Saddam Hussain v. State of M.P²⁰

¹⁷ Ms. Saumya Uma, Outlawing Cyber Crimes Against Women In India, Bharati Law Review, April – June, 2017, www.manupatra.com

¹⁸ CC no. 4680 of 2004

¹⁹ T.E. Raja Simhan,India Ranks Third in Cyber Bullying, BUSINESS LINE, June 26, 2012.

²⁰ 2016 SCC Online MP 1471 (India).

Accuse outraged the modesty of the victim, video recorded the same on his phone and used the same to blackmail her. In Shreya Singhal v. Union of India²¹

There was compromise between victim and accused on the charges of harassment by the accused on online platform. The high court rejected the plea for revoke the case on the ground that , the crime is not only against a specific woman but it is against the society at large so personal compromise would not affect the continuation of the prosecution.

EMAIL SPOOFING AND IMPERSONATION

Deceptive email activity in which sender address and other parts of origin of mail tainted so mail seems to be unknown destination. Hacker may change the properties of mail like its header, return path, and reply etc so it will appear from someone mail other than sender address. While using this technique culprit may involve into crime like harassing the victim, sending unknown and obscene message, harassment messages or blackmail the victim for physical, economical or physiological benefits.

Manish kathuria case in 2001, who harassed the victim (Ritu kohli) on chat room, distributed her phone number in public due to that she was receiving phone calls from unknown numbers. But delhi police arrested him under IPC for outraged the modesty of women, but not prosecuted under actual crime because of want of proper legal provision.

Law:

(S. 415 IPC) : cheating by personation

(S. 416 IPC): ‘Cheating by personation’ entails cheating by pretending to be some other person, or representing himself to be a person that he is not.

S. 66D of the IT Act also provides for punishment for cheating by personation by using communication device or a computer resource. It is an offence punishable with up to three years imprisonment and fine of up to Rupees one lakh under the IT Act.

Phishing: try to get sensitive information of the victim such as Account and password, and then new post which is derogatory to victim can be posted on victim social account.

Trolling: this is very familiar those who have account on social website like twitter, here also criminal may start quarrelling or upset the victim while using dislike language against victim.

ISSUES RELATING CYBER CRIME AND PROVISION OF LAW

Whether intermediaries are required to remove content instantly?

Supreme Court read down in Shreya Singhal v. Union of India²² the scope of ‘actual knowledge’ as used in Clause (b) of Sub-section (3) of Section 79 of the IT Act to “receiving actual knowledge from a court order or on being notified by the appropriate government or its agency”. Thus, the question whether the intermediaries are required to remove offending content on an order of court or appropriate government and its agencies is no longer res integra.

But still there is no law available relating removing content online platform, express provision not available. X vs. State and Ors²³

The petitioner has filed the petition in Delhi High Court for directions be issued against respondent nos. 2 to 4 to remove WebPages.

She states that in the year 2012, she was sixteen years old and was studying in a well-known School in Delhi. She came to be acquainted with an accused boy, who was studying in the same class. And, within a short span of time she became very

²¹ (2015) 5 SCC 1; AIR 2015 SC 1523; MANU/SC/0329/2015

²² (2015) 5 SCC 1; AIR 2015 SC 1523; MANU/SC/0329/2015

²³ (20.10.2020 – DELHC) : MANU/DE/1903/2020

close friends with him. She alleges that the accused started emotionally blackmailing her and compelled her to send her intimate photographs to him. He threatened that if she didn’t, he would commit suicide. She surrendered to the said tactics and started sending him her “intimate pictures”. She states that the relationship with the Accused was very abusive and therefore, she broke up her relations with him.

After completing her schooling, she secured admission in University of Bath, United Kingdom and in August, 2014 she proceeded to the UK for further studies. She used to avoid his calls but he would persist by calling her from unknown numbers. She states that one day he landed up at her residence in Bath, U.K. and physically assaulted her. She alleges that he tried to throttle her; he placed a knife on her neck; and threatened to kill her. The petitioner was constrained to lodge a police complaint against the Accused. The matter was brought before the Magistrate Court of the Province of Bath, United Kingdom. The Accused pleaded guilty and on 04.01.2017, the Court passed an order restraining the accused from contacting the petitioner by any means including electronic, means for a period of two years, that is, till 04.01.2019. In addition, the Accused was also restrained from entering the City of Bath for a period of two years.

The Accused returned to India in the year 2017. The petitioner states that in the year 2019, she decided to proceed to Melbourne, Australia for higher studies. She claims that in October–November 2019, she became aware that the Accused had posted her intimate pictures on various platforms such as Twitter, Instagram, YouTube, etc. She claims that the photographs uploaded were the same that were sent by her to the Accused when she was a minor and the Accused had misused the said photographs and placed them on the internet.

After becoming aware that the Accused had placed her photographs on the net, the petitioner filed a complaint against the Accused before the Special Cell, Cyber Crime Department Delhi Police. Pursuant to the said complaint, an FIR bearing No. 129/2019 for commission of offence punishable under Section 67-67A of the Information and Technology Act, 2000 was registered.

The petitioner also sent notices to respondent nos. 2 to 4 through her advocates calling upon them to immediately remove the WebPages containing her objectionable photographs. She contends that despite forwarding the same, the said WebPages/URLs were not removed from the platforms provided by the respondent nos. 2 to 4.

The petitioner has mentioned forty such URLs (on the platform under the control of respondent no. 2-Facebook Inc). She has also mentioned nine URLs on the platform www.youtube.com (YouTube) which is hosted by respondent no. 3- Google LLC and two WebPages posted on the platform of respondent no. 4 (Telegram).

Right to privacy vs. Social Morality

Supreme Court of India in the case of Mr. ‘X’ v. Hospital ‘Z’²⁴ has recognized an individual’s right to privacy as a facet Article 21 of the Constitution of India. It was also pertinently held that the right which would advance the public morality or public interest would alone be enforced through the process of court, for the reason that moral considerations cannot be kept at bay and the Judges are not expected to sit as mute structures of clay in the halls known as the courtroom, but have to be sensitive, “in the sense that they must keep their fingers firmly upon the pulse of the accepted morality of the day.”

²⁴ (1998) 8 SCC 296

Vasunathan v. The Registrar General²⁵, has also recognized the “right to be forgotten” and ‘Right to be left alone’ as an integral to part of individual’s existence. Supreme Court held in²⁶ that purpose limitation is integral for executive projects involving data collection-unless prior permission is provided, third parties cannot be provided access to personal data.

Right to Freedom of expression vs. Public Good

Fathima A.S. v. State of Kerala and Ors²⁷ In this case social worker posted two children (girl and boy) nude photo painting on online platform so case was file against her on the ground of violating public morality and law relating to children. Where contentions raised by the petitioner in this case,

“When Compare to Male body, Feminine body and her Nakedness has been considered as a mere 55kg of Flesh is just because of the wrong Sexual Education put forward by our society. Society has Customized the Mindset of people in such a way that while looking at a woman who wear a legging make you Sexual arousal whereas the man Stands Macho with his Chest-Hair Exposed as well as showing naked legs by folding the dhoti he wears as a statuesque, doesn’t Connect to Sexual Arousal is just because of the wrong sexual consciousness that is currently being injected by the society. Just as beauty is in the eye of the beholder, so is obscenity in the eyes of the beholder…….The women have to start sharpen her weapons to sew the Cloth for nakedness.”

CONCLUSION

Under the Indian Criminal Justice system a strong penal action is prescribed against the accused for such heinous crime but there is no mechanism available with respect to the right of the victim to get the objectionable photographs deleted from the online platform.

No provision IPC and IT act for ground realities of women experiences. Procedural hurdles also are in the way of justice to women.

If any photographs posted on International porn site then there is no mechanism available in India to delete that photographs or video.

The woman aware about to how to use the online platforms but they are not aware about what to do after caught in difficult situation and cyber crimes. Women shall take caution before posting own or love ones photographs or video, at least they shall confer password for online material which is going to publish in online. Change password time to time.

²⁵ See also, Zulfiqar Ahman Khan v. Quintillion Business Media Pvt. Ltd. and Ors. 2019(175) DRJ 66.; High Court of Gujarat in Dharamraj Bhanushankar Dave v. State of Gujarat & Ors.,; Supreme Court of India in the case of K.S. Puttaswamy v. Union of India

²⁶ K.S. Puttaswamy v. Union of India (2017) 10 SCC 1.

²⁷ (24.07.2020 – KERHC) : MANU/KE/2706/2020