(a) It is a closed legislation only recognises Digital Signature that too in a particular format. It does not cater to technological advancements and changes like biometric signatures, smartcards, transactions through the net on credit cards not using digital signatures but using passwords like PKN etc. The suggestion is that the Act should be more open and versatile and cover as much as possible instead of restricting itself to "digital signatures" as defined. 

(b) Since the liabilities and entitlements on the net legally and commercially differ from the normal world in physical space, the ultimate enforcement of these rights and liabilities should also be easier and different. That is instead of falling back upon the traditional court system, some internet legal system like that of WIPO for domain name disputes should be made available. This would not only increase commercial confidence in the transactions on the net but also make the system faster and economical. Since the enforcement is on the net, Court fees can also be charged according to the value of the claim in order to sustain the system.

(c) Another major flaw in the Act is: what happens when the certificate holder dies. It should be deemed to have become non-est as well as the heirs should be made responsible to inform the certification authority about the death of the certificate holder. Further use of the certificate after the person's death may put the Certification Authority into legal trouble just in the case of Notaries and Oath Commissioners (who also do the same function essentially showing that the person who has signed the document exists and has signed the said document in front of the said person).

(d) What happens to the certificates issued by a Certification Authority whose license is suspended under the Act. Will the certificates still hold good or will they become non-est.

These are some of the major issues according to me. I am certain in case you start digging you will find much more material. In case I find some more flaws, I will certainly post them to you. But please see that these issues are resolved so that the law becomes more effective and forceful. In case you require any further clarification you may contact me on my following address or my email that is rishiagrawala@usa.net

Rishi Agrawala 
34, Babar Lane 
Bengali Market 
New Delhi.