Centre for Internet and Society

India's Biometric Identification Programs and Privacy Concerns

divij — 2016-07-21T10:51:42Z

The invasiveness of individual identification coupled with the fallibility of managing big data which biometric identification presents poses a huge risk to individual privacy in India.

Divij Joshi is a 2nd year at NLS. He is interning with the Centre for Internet and Society for the privacy project. This research was undertaken as part of the 'SAFEGUARDS' project that CIS is undertaking with Privacy International and IDRC.

Introduction

Biometric technology looks to be the way ahead for the Indian government in its initiatives towards identification. From the Unique Identity Scheme (Aadhaar) to the National Population Register and now to Election ID’s, [1] biometric identification seems to have become the government’s new go-to solution for all kinds of problems. Biometrics prove to be an obvious choice in individual identification schemes – it’s easiest to identify different individuals by their faces and fingerprints, unique and integral aspects of individuals – yet, the unflinching optimism in the use of biometric technology and the collection of biometric data on a massive scale masks several concerns regarding compromises of individual privacy.

‘Big Data’ and Privacy Issues

Biometric data is going to be collected under several existing and proposed identification schemes of the government, from the Centralized Identities Data Register of the UID to the draft DNA Profiling Bill which seeks to improve criminal forensics and identification. With the completion of the biometric profiling under the UID, the Indian government will have the largest database of personal biometric data in the world. [3] With plans for the UID to be used for several different purposes — as a ration card, for opening a banking account, for social security and healthcare and several new proposed uses emerging everyday,[1] the creation of ‘Big Data’ becomes possible. ‘Big Data’ is characterized by the volume of information that is produced, the velocity by which data is produced, the variety of data produced and the ability to draw new conclusions from an analysis of the data.[2] The UID will generate “Big Data” as it is envisioned that the number will be used in every transaction for any platform that adopts it — for all of the 1.2 billion citizens of India. In this way the UID is different any other identity scheme in India, where the identifier is used for a specific purpose at a specific point of time, by a specific platform, and generates data only in connection to that service. Though the creation of “Big Data” through the UID could be beneficial through analysing data trends to target improved services, for example, at the same time it can be problematic in case of a compromise or breach, or if generated information is analyzed to draw new and unintended conclusions about individuals without their consent, and using information for purposes the individuals did not mean for it to be used.

Biometric ID and Theft of Private Data

The government has touted identification schemes such as the UID and NPR as a tool to tackle rural poverty, illegal immigration and national security issues and with this as the premise, the concerns about privacy seem to have been left in the lurch. The optimism driving the programmes also means that its potential fallibility is often overlooked in the process. Biometric technology has been proven time and again to be just as easily jeopardized as any other and the threat of biometric identity theft is as real and common as something like credit card fraud, with fingerprints and iris scans being easily capable of replication and theft without the individual owners consent. [2] In fact, compromise or theft of biometric identity data presents an even greater difficulty than other forms of ID because of the fact that it is unique and intrinsic, and hence, once lost cannot be re-issued or reclaimed like traditional identification like a PIN, leaving the individual victim with no alternative system for identification or authentication. This would also defeat the entire purpose behind any authentication and identification schemes. With the amount of personal data that the government plans to store in databases using biometrics, and without adequate safeguards which can be publicly scrutinized, using this technology would be a premature and unsafe move.

Biometric data and Potential Misuse

Centralised data storage is problematic not only for the issues with data compromise and identity theft, but the problems of potential third-party misuse in the absence of an adequate legal framework for protecting such personal data, and proper technical safeguards for the same, as has been pointed out by the Standing Committee on Finance in its report on the UIDAI project.[4] The threat to privacy which these massive centralized databases pose has led to the shelving of similar programmes in England as well as France. [4] Further, concerns have been voiced about data sharing and access to the information contained in the biometric database. The biometric database is to be managed by several contracting companies based in the US. These same companies have legal obligations to share any data with the US government and Homeland Security. [5]

A second, growing concern over biometric identification schemes is over the use of biometrics for state surveillance purposes. While the UID’s chief concern on paper has been development, poverty, and corruption alleviation, there is no defined law or mandate which restricts the number from being used for other purposes, hence giving rise to concerns of a function creep - a shift in the use of the UID from its original intended purpose. For example, the Kerala government has recently proposed a scheme whereby the UID would be used to track school children.[5] Other schemes such as the National Population Register and the DNA Profiling Bill have been specifically set up with security of the State as the mandate and aim.[6] With the precise and accurate identification which biometrics offers, it also means that individuals are that much easier to continuously survey and track, for example, by using CCTV cameras with facial recognition software, the state could have real-time surveillance over any activities of any individual.[7]

With all kinds of information about individuals connected by a single identifier, from bank accounts to residential and voter information, the threat of increased state surveillance, and misuse of information becomes more and more pronounced. By using personal identifiers like fingerprints or iris scans, agencies can potentially converge data collected across databases, and use it for different purposes. It also means that individuals can potentially be profiled through the information provided from their various databases, accessed through identifiers, which leads to concerns about surveillance and tracking, without the individuals knowledge. There are no Indian laws or policies under data collection schemes which address concerns of using personal identifiers for tracking and surveillance.[8] Even if such such use is essential for increased national security, the implementation of biometrics for constant surveillance under the present regime ,where individuals are not notified about the kind of data being collected and for what its being used, would be a huge affront on civil liberties, as well as the Right to Privacy, and prove to be a powerful and destructive weapon in the hands of a police state. Without these concerns being addressed by a suitable, publicly available policy, it could pose a huge threat to individual privacy in the country. As was noted by the Deputy Prime Minister of the UK, Nick Clegg, in a speech where he denounced the Identity Scheme of the British government, saying that “This government will end the culture of spying on its citizens. It is outrageous that decent, law-abiding people are regularly treated as if they have something to hide. It has to stop. So there will be no ID card scheme. No national identity register, a halt to second generation biometric passports.” [6]

Biometric technology has been useful in several programmes and policies where its use has been open to scrutiny and restricted to a specific function, for example, the recent use of facial recognition in Goa to tackle voter fraud, and similar schemes being taken up by the Election Commission. [7] However, with lack of any guidelines or specific legal framework covering the implementation and collection of biometric data schemes, such schemes can quickly turn into ‘biohazards’ for personal liberty and individual privacy, as has been highlighted above and these issues must be brought to light and adequately addressed before the Government progresses on biometric frontiers.

[1]. http://www.goacom.com/goa-news-highlights/3520-biometric-scanners-to-be-used-for-elections.

[2]. http://www.wired.com/threatlevel/2008/03/hackers-publish.

[3].https://www.eff.org/deeplinks/2012/09/indias-gargantuan-biometric-database-raises-big-questions.

[4]. http://www.informationweek.com/security/privacy/britain-scraps-biometric-national-id-car/228801001.

[5]. http://www.thehindu.com/opinion/op-ed/questions-for-mr-nilekani/article4382953.ece.

[6]. http://news.bbc.co.uk/2/hi/8691753.stm

[7]. Supra note 1.

For more details visit https://cis-india.org/internet-governance/blog/indias-biometric-identification-programs-and-privacy-concerns

The Surveillance and Security Industry in India - An Analysis of Indian Security Expos

divij — 2015-03-14T02:56:35Z

For more details visit https://cis-india.org/internet-governance/blog/surveillance-and-security-industry-in-india.pdf

New Standard Operating Procedures for Lawful Interception and Monitoring

divij — 2014-03-20T05:13:13Z

Government issues new guidelines to TSP’s to assist Lawful Interception and Monitoring.

Even as the Central Government prepares the Central Monitoring System for the unrestricted monitoring of all personal communication, the Department of Telecom has issued new guidelines for Telecom Service Providers to assist in responding to requests for interception and monitoring of communications from security agencies.

These guidelines do not appear to be publicly accessible, but according to news items, under the “Standard Operating Procedures for Lawful Interception and Monitoring of Telecom Service Providers”, the TSP’s must now provide for lawful interception and monitoring requests for voice calls, Short message Service (SMS), General Packet Radio Service (GPRS) and Value Added Service (VAS) including Multi Message Service (MMS), data and voice in 3G/4G/Long Term Evolution (LTE) including video call or Voice Over Internet protocol (VoIP). This move comes just days after the Home Ministry suggested that the Department of Telecom either change the rules under their Telecom Policies such as the Unified Access Service Licence (UASL) to include VoIP monitoring, or, drastically, block all VoIP services on the internet, which would include several communication applications including Skype and GTalk. (See the article published by Economic Times).

The guidelines will supposedly also provide for some basic safeguards to ensure that non-authorized interception does not take place, such as ensuring that the interception is only to be provided by the Chief Nodal Officer of a TSP and only upon the issue of an order by the Home Secretary at the Central or State Government. Furthermore, these requests must only be in written, in untampered and sealed envelopes with no overwriting, etc. and bearing the order number issued by the concerned Secretary, with the date of the order. However, in exigent circumstances the order may be provided by email, provided that the physical copy is sent within two days of the order, else the interception order must be terminated. Inquiry processes are detailed under the new SOP’s which can verify whether the request was in original and addressed to the Nodal Officer and from which designated security agency it was issued, and can also verify the issue of an acknowledgment of compliance of the order by the TSP within two days of its receipt. The new guidelines also clarify the issue of interception of roaming subscribers by the State Government where the subscriber is registered. According to the guidelines, an order by the government of the state where such a caller has registered is sufficient and does not need vetting by the Home Secretary at the centre.

Notwithstanding the additional “safeguards” against unlawful or unauthorized interception, the message to take away from these guidelines is the Government’s continued efforts to expand its surveillance regime to comprehensively monitor every action and every communication at its whim. These requests for monitoring, undertaken by “security agencies” which include taxation agencies and the SEBI, are flawed not merely because of the possibility of “unauthorized” interception, rather because the legal basis of the interception is vague, broad and widely susceptible to misuse, as the recent “snoopgate” allegations against the Gujarat government have shown. (See the article published by the Hindu).

The current regime, based on a wide interpretation of Section 5(2) of the Indian Telegraph Act and the telecom policies of the Department of Telecom, do not have adequate safeguards for preventing misuse by those in power – such as the requirement of reasonable suspicion or a warrant. Without a sound legal basis for interception, which protects the privacy rights of individuals, any additional safeguards are more or less moot, since the real threat of intrusive surveillance and infringing of basic privacy exists regardless of whether it is done under the seal of the Home Secretary or not.

Resources

For more details visit https://cis-india.org/internet-governance/blog/new-standard-operating-procedures-for-lawful-interception-and-monitoring

A Review of the Functioning of the Cyber Appellate Tribunal and Adjudicatory Officers under the IT Act

divij — 2014-07-03T05:43:23Z

Tribunals and quasi-judicial bodies are a regular feature of the Indian judicial system, as they provide for easier and less onerous methods for dispute resolution, especially disputes which relate to technical areas and often require technical knowledge and familiarity with specialised factual scenarios.

Further, quasi-judicial bodies do not have the same procedural restrictions as proper courts, which makes the adjudication of disputes easier. The Information Technology Act of India, which regulates several important aspects of electronic information, including the regulation of private electronic transactions as well as detailing civil and criminal offences relating to computers and electronic information, contemplates a specialised dispute resolution mechanism for disputes relating to the offences detailed under the Act. The Act provides for the establishment of quasi-judicial bodies, namely adjudicating officers under S.46, to hear disputes arising out of Chapter IX of the Act, namely, offences of a civil nature under S.43, 43A, 44 and 45 of the Act, as well as criminal offences described under Chapter XI of the Act. The adjudicating officer has the power to both award compensation as damages in a civil remedy, as well as impose penalties for the contravention of the Act,[1] and therefore has powers of both civil and criminal courts. The first appellate body provided in the Act, i.e. the authority that any party not satisfied by the decision of the adjudicating officer can appeal to, is the Cyber Appellate Tribunal, consisting of a Chairperson and any other members so prescribed by the Central Government.[2] The second appeal, if a party is aggrieved by the decision of the Cyber Appellate Tribunal, may be filed before the High Court having jurisdiction, within 60 days from the date of communication of the order.[3]

Functioning of the Offices of the State Adjudicating Officers and the Cyber Appellate Tribunal

The office of the adjudicating officer is established under S.46 of the IT Act, which provides that the person appointed to such a post must be a government officer of a rank not below that of a Director or an equivalent rank, and must have experience both in the field of Information Technology as well as legal or judicial experience.[4] In most cases, the appointed adjudicating officer is the Principle Secretary to the Department of Information Technology in the state.[5] The decisions of these adjudicating officers determine the scope and meaning of several provisions of the IT Act, and are instrumental in the development of the law in this field and filling a lacuna regarding the interpretation of these important provisions, particularly in areas such as data protection and privacy.[6] However, despite the large number of cyber-crime cases being registered across the country,[7] there is a lack of available judgements on the adjudication of disputes under Sections 43, 43A, 44 and 45 of the Act. Of all the states, only the websites of the Departments of Information Technology in Maharashtra,[8], Tamil Nadu[9], New Delhi[10], and Haryana[11] have reported judgements or orders of the Adjudicating Officers. The adjudicating officer in Maharasthra, Rajesh Aggarwal, has done a particularly commendable job, having disposed of 51 cases under the IT Act, with 20 cases still pending.

The first Cyber Appellate Tribunal set up by the Central Government is located at New Delhi. Although a second branch of the Tribunal was to be set up in Bangalore, no efforts seem to have been made in this regard.[12] Further, the position of the Chairperson of the Appellate Tribunal, has been left vacant since 2011, after the appointed Chairperson attained the age of superannuation and retired. Although judicial and technical members have been appointed at various points, the tribunal cannot hold hearings without a chairperson. A total of 17 judgements have been passed by the Cyber Appellate Tribunal prior to the retirement of the chairperson, while the backlog of cases is continuously growing.[13] Despite a writ petition being filed before the Karnataka High Court and the secretary of the Department of IT coming on record to state that the Chairperson would be appointed within 6 months (of September 2013), no action seems to have been taken in this regard, and the lacunae in the judicial mechanism under the IT Act continues. The proper functioning of adjudicating officers and the Cyber Appellate Tribunal is particularly necessary for the functioning of a just judicial system in light of the provisions of the Act (namely, Section 61) which bar the jurisdiction of ordinary civil courts in claims below the amount of Rs. 5 Crores, where the adjudicating officer or the CAT is empowered.[14]

Analysis of Cases Filed under Section 43A

Section 43A of the Information Technology Act was inserted by the 2008 Amendment, and is the principle provision governing protection of information held by intermediaries under the Act. Section 43A provides that “body corporates” handling “sensitive personal data” must implement reasonable security practices for the protection of this information. If it is negligent in providing or maintaining such reasonable security practices, the body corporate is to be held liable and must pay compensation for the loss occurred.[15] Rule 3 of the Draft Reasonable Security Practices Rules, defines sensitive personal data as including – passwords, user details as provided at the time of registration or thereafter, information related to financial information such as Bank account/ credit card /debit card /other payment instrument details of the users, physiological and mental health conditions, medical records and history, biometric information, information received by body corporate for processing, stored or processed under lawful contract or otherwise and call data records.[16]

All the decisions of appointed adjudicators are available for an analysis of Section 43A are from the adjudicating officer in Maharashtra, Mr. Rajesh Tandon, who despite having no judicial experience, has very cogent analysis and knowledge of legal issues involved in the cases, which is commendable for a quasi-judicial officer.

One class of cases, constituting a major chunk of the claims, is where the complainant is claiming against a bank for the fraudulent transfer of funds from the claimants account to another account. In most of these cases, the adjudicating officer examined the compliance of the bank with “Know Your Customer” norms and guidelines framed by the Reserve Bank of India for prevention of banking fraud and, where such compliance was found to be lacking and information which allowed the bank accounts of the complainant was allowed to be accessed by fraudsters, the presumption is that the bank was negligent in the handling of “sensitive personal information”,[17] by failing to provide for reasonable security practices and consequently was liable for compensation under S.43A, notwithstanding that the complainant also contributed to compromising certain personal information by responding to phishing mails,[18] or divulging information to other third parties.[19] These instances clearly fall within the scope of Section 43A, which protects “information related to financial information such as Bank account/ credit card /debit card /other payment instrument details of the users” as sensitive personal data from negligent handling by body corporates. The decisions of the adjudicating officer must be applauded for placing a higher duty of care on banks to protect informational privacy of its customers, given that they are in a position where they ought to be well equipped to deal with intimate financial information and holding them accountable for lack of proper mechanisms to counter bank fraud using stolen information, which reflects in the compensation which the banks have been liable to pay, not only as indemnification for losses, but also punitive damages.[20]

In Nirmalkumar Bhagerwal v IDBI Bank and Meenal Bhagerwal, the sensitive financial information of the complainant, namely, the bank statement, had been accessed by the complainants wife. In holding the bank to be liable for divulging the same, and that access to personal information by a spouse is also covered under S.43A, the officer seems to have imputed the loss of privacy on account of such negligence as ‘wrongful loss’ which deserves compensation. One anomalous decision of the officer was where the operator of an ATM was held liable for fraudulent credit card transactions in that Machine, due to “reasonable security practices” such as security personnel or CCTV footage, and therefore causing the loss of “sensitive personal data”. However, it is difficult to see how ATM operators can be held liable for failing to protect sensitive information from being divulged, when the case is simply of a person fraudulently using a credit card.

Another class of cases, generally linked with the above cases, is complaints against cell phone providers for divulging information through falsely procured Sim Cards. In such instances, the officer has held that by negligently allowing the issuance of duplicate sim cards, the phone company has led to the access of sensitive personal data and thus caused wrongful loss to the complainant. This interpretation of Section 43A is somewhat confusing. The officer seems to have interpreted the provisions of Section 43A to include carriers of the information which was originally sent through the computer resource of the banking companies. In this way, they are imputed the status of “handlers” of sensitive personal information, and their communications infrastructure through which the information is sent is the “computer resource” which it operates for the purpose of the Act. Therefore, through their negligence, they are abetting the offence under 43A.[21]

For example, in the case of Sanjay Govind Dhandhe v ICICI and Vodafone, the officer remarked that –“A SIM card is a veritable key to person’s sensitive financial and personal information. Realizing this, there are clear guidelines issued by the DOT regarding the issuance of SIM cards. The IT Act also intends to ensure that electronic personal and sensitive data is kept secured and reasonable measures are used to maintain its confidentiality and integrity. It is extremely crucial that Telecom companies actively follow strict security procedures while issuing SIM cards, especially in wake of the fact that mobiles are being increasingly used to undertake financial transactions. In many a case brought before me, financial frauds have been committed by fraudsters using the registered mobile numbers of the banks’ account holders.” Therefore, intermediaries such as telecom companies, which peripherally handle the data, are also liable under the same standards for ensuring its privacy. The adjudicating officer has also held telephone companies liable for itemized phone bills as Call Data Records negligently divulged by them, which again clearly falls under the scope of the Reasonable Security Practices Rules.[22]

Note:

"Credentek v Insolutions (http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_Credentek_Vs_Insolutions-28012014.pdf) . This case holds that banks and the National Payments Corporation of India were liable under S. 43A for divulging information relating to transactions by their customers to a software company which provides services to these banks using the data, without first making them sign non-disclosure agreements. The NCPI was fined a nominal amount of Rs. 10,000."

[1]. Section 46, Information Technology Act, 2000.

[2]. Section 48 and 49 of the Information Technology Act, 2000 (Amended as of 2008).

[3]. Section 62, IT Act. However, The High Court may extend this period if there was sufficient cause for the delay.

[4]. S. 46(3), Information Technology Act, “No person shall be appointed as an adjudicating officer unless he possesses such experience in the field of Information Technology and Legal or Judicial experience as may be prescribed by the Central Government.”

[5]. From whatever data is available, the adjudicating officers in the states of Maharashtra, New Delhi, Haryana, Tamil Nadu and Karnataka are all secretaries to the respective state departments relating to IT.

[6]. See http://cis-india.org/internet-governance/blog/analysis-of-cases-filed-under-sec-48-it-act-for-adjudication-maharashtra; Also see the decision of the Karnataka adjudicating officer which held that body corporates are not persons under S.43 of the IT Act, and thus cannot be liable for compensation or even criminal action for offences under that Section, available at http://www.naavi.org/cl_editorial_13/adjudication_gpl_mnv.pdf.

[7]. Maharashtra Leads in War Against Cyber Crime, The Times of India, available at http://timesofindia.indiatimes.com/city/mumbai/Maharashtra-leads-in-war-against-cyber-crime/articleshow/30579310.cms. (18^th February, 2014).

[8]. https://it.maharashtra.gov.in/1089/IT-Act-Judgements

[9]. http://www.tn.gov.in/documents/atoz/J

[10]. http://www.delhi.gov.in/wps/wcm/connect/DoIT_IT/doit_it/it+home/orders+of+adjudicating+officer

[11]. http://haryanait.gov.in/cyber.htm

[12]. Bangalore Likely to host southern chapter of Cyber Appellate Tribunal, The Hinduk http://www.thehindu.com/news/national/karnataka/bangalore-is-likely-to-host-southern-chapter-of-cyber-appellate-tribunal/article3381091.ece (2^nd May, 2013).

[13]. http://catindia.gov.in/Judgement.aspx

[14]. Section 61 of the IT Act – ‘No court shall have jurisdiction to entertain any suit or proceeding in respect of any matter which an adjudicating officer appointed under this Act or the Cyber Appellate Tribunal constituted under this Act is empowered by or under this Act to determine and no injunction shall be granted by any court or other authority in respect of any action taken or to be taken in pursuance of any power conferred by or under this Act. Provided that the court may exercise jurisdiction in cases where the claim for injury or damage suffered by any person exceeds the maximum amount which can be awarded under this Chapter.’

[15]. Section 43A, Information Technology Act, 2000 – ‘Compensation for failure to protect data (Inserted vide ITAA 2006) Where a body corporate, possessing, dealing or handling any sensitive personal data or information in a computer resource which it owns, controls or operates, is negligent in implementing and maintaining reasonable security practices and procedures and thereby causes wrongful loss or wrongful gain to any person, such body corporate shall be liable to pay damages by way of compensation, to the person so affected. (Change vide ITAA 2008)

Explanation: For the purposes of this section (i) "body corporate" means any company and includes a firm, sole proprietorship or other association of individuals engaged in commercial or professional activities (ii) "reasonable security practices and procedures" means security practices and procedures designed to protect such information from unauthorized access, damage, use, modification, disclosure or impairment, as may be specified in an agreement between the parties or as may be specified in any law for the time being in force and in the absence of such agreement or any law, such reasonable security practices and procedures, as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit. (iii) "sensitive personal data or information" means such personal information as may be prescribed by the Central Government in consultation with such professional bodies or associations as it may deem fit.

[16]. Draft Reasonable Security Practices Rules under Section 43A of the IT Act, available at http://www.huntonfiles.com/files/webupload/PrivacyLaw_Reasonable_Security_Practices_Sensitive_Personal_Information.pdf.

[17]. Ravindra Gunale v Bank of Maharashtra, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RavindraGunale_Vs_BoM&Vodafone_20022013.PDF. Ram Techno Pack v State Bank of India, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RamTechno_Vs_SBI-22022013.pdf.

Srinivas Signs v IDBI, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_SreenivasSigns_Vs_IDBI-18022014.PDF.

Raju Dada Raut v ICICI Bank, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RajuDadaRaut_Vs_ICICIBank-13022013.pdf

Pravin Parkhi v SBI Cards, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_PravinParkhi_Vs_SBICardsPayment-30122013.PDF.

[18]. Sourabh Jain v ICICI, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_SourabhJain_Vs_ICICI&Idea-22022013.PDF.

[19]. Poona Automobiles v Punjab National Bank, https://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_PoonaAuto_Vs_PNB-22022013.PDF

[20]. Amit Patwardhan v Bank of Baroda, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudicaton_AmitPatwardhan_Vs_BankOfBaroda-30122013.PDF.

[21]. Ravindra Gunale v Bank of Maharashtra, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RavindraGunale_Vs_BoM&Vodafone_20022013; Raju Dada Raut v ICICI Bank, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RajuDadaRaut_Vs_ICICIBank-13022013.pdf.

[22]. Rohit Maheshwari v Vodafone, http://it.maharashtra.gov.in/Site/Upload/ACT/DIT_Adjudication_RohitMaheshwari_Vs_Vodafone&ors-04022014.PDF.

For more details visit https://cis-india.org/internet-governance/blog/review-of-functioning-of-cyber-appellate-tribunal-and-adjudicatory-officers-under-it-act