Hats off to the Kerala Judgement on Right to Forget-3: Right to Forget is not Right to Anonymity..

[This is a continuation of our earlier article on the Kerala Judgement on Right to Forget]

The Judgment of Kerala Hight Court of 22nd December 2022 in the WP (C) nos 26500/2020 & connected cases  was mainly considering the issue of “Right to Forget” and whether it is to be recognized by removal of the identity of parties from published judgements in different contexts.

The Court considered the issue from four different aspects namely Privacy, Courts as democratic institutions,  Open Data and Public Interest.

Definition of Privacy

The Court took the Definition of Privacy as a Right as the starting point for the debate on Right to be forgotten and has recorded its views. In the process, the judgement has traced the evolution of the definition of Privacy and contributed to the discussion of the “Theory of Privacy”, which is a concept of exploratory interest for us.

The judgement traces the development of Privacy thus:

“In very early times, the law gave a remedy only for physical interference with life and property, for trespasses vi et armis. Then the “right to life” served only to protect the subject from battery in its various forms; liberty meant freedom from actual restraint; and the right to property secured to the individual his lands and his cattle. 

Later, there came a recognition of man’s spiritual nature, of his feelings and his intellect.

Gradually the scope of these legal rights broadened; and now the right to life has come to mean the right to enjoy life,-the right to be let alone; the right to liberty secures the exercise of extensive civil privileges; and the term “property” has grown to comprise every form of possession-intangible, as well as tangible. “

In the process of this development it was recognised that writings or opinions of an individual though not in reality his private property, was considered as an inviolate personality.

The evolution of the definition of privacy then inevitably moves into the domain of technology and the special issues that the virtual space has created as if the definition of privacy is inseparable from the Technology space. It is recognized that Virtual Space has made identity of the individual digitally immortal and Digital immortality defines the continuation of an active or passive digital presence even after death.

As a result new issues of Right to Privacy has arisen and the social and ethical problems in relation to digital immorality and artificial intelligence which can identify the data stored through algorithms are the subject matter of debate of Privacy.

The current problem of “Right to Forget” is traced to this development where there is an intersection of privacy and technology which has become a challenge for the  judicial administrator.

It is through this “Digital Immortality” argument (which is a combination of data storage, capability of being indexed, searched and retrieved easily) that the “Right to Forget” discussion has been linked to “Information Privacy” in this judgement. Hence this discussion may be considered as part of the ratio decidendi and not only orbiter dicta as far as this case is considered.

The Court recognized that there are different dimensions of the information before Courts which play an integral role in encouraging fair and transparent decision making by the Courts, giving them legitimacy and contributing to the dissemination of information about the judicial process among the public.

The judgement also makes an interesting reference to the part of the Puttaswamy judgement where a distinction is sought to be made between “Privacy” and “Anonymity”.

According to Justice Chandrachud,  “Privacy involves hiding information whereas anonymity involves hiding what makes it personal”.

The Kerala Judgement points out that Privacy is about choice and this choice is sought to be extended as anonymity in court proceedings. It also underscores that “Privacy in the judicial information context is essentially related to the contents of the information in the case. Anonymity on the other hand, in the judicial information sphere, is a process of denying information to the public about the identity of the parties related to a case”.

The Court went on to add…

“Undoubtedly, we have to hold that personal information as above, of the parties in a case, has to be classified as data forming part of his or her privacy. The individual’s right to exercise control over his personal data and to be able to control his/her own life has been recognized in Justice K.S.Puttaswamy’s case (supra) in the separate judgment authored by Justice Sanjay Kishan Kaul without recognizing it as an absolute right…..

The existence of such a right does not imply that a criminal can obliterate his past, but that there are variant degrees of mistakes, small and big and it cannot be said that a person should be profiled to the nth extent for all and sundry to know.

The interplay of providing information about the parties and providing information on the contents of the cause in a Court of law requires a balancing exercise. It is exactly that exercise that has to be considered by this Court in these writ petitions in the absence of any legislation.

No one has any grievance against the open, transparent court proceedings and the conduct of cases in the open justice system. The problem for them is allowing their personal and private information to remain permanently in the digital public space, invading their right to privacy and right to forget the past. The task for us, therefore, is to decide not only on the privacy claimed in the present but also in the future.”

The Learnings to be taken note of

Thus it can be observed that the Court has flagged the “Data Storage and Data Retrieval” as the Privacy Risks than the data itself.

It is this aspect that we need to consider the “Right to Erase” and “Right to Forget” as two different concepts in DPDPB 2022. When data is made retrievable by public which is essentially related to “Disclosure” of personal data, the need for recognizing the risk of unfair privacy risk arises.

At the same time, ” Right to Forget” cannot be considered as the “Right to become anonymous” and hence it is to be considered as a limited right to prevent free disclosures.

“Right to Erase” on the other hand is related to the purpose oriented collection and use principle and requires that once the purpose is completed, the personal information should be stopped from being processed. This does not mean that the data has to be “Anonymized” or “Purged irretrievably”.

The Data Fiduciary can retain the purpose-expired data and such data can be retrieved and disclosed in certain circumstances such as there is a request for legitimate purpose.

When data has been archived as purpose-expired, it is debatable if the “Disclosure” needs to be blocked automatically for search and retrieval since there may be a public interest in the information with or without identity.

If however “Right to forget” is recognized and the data principal has placed his “request for right to forget”, then it may be appropriate to block automated disclosure.

Even in such cases, since “Right to Forget” is not “Right to Anonymity”,  it may be in order to exempt the restriction to the disclosure to law enforcement agencies or on orders of Court or in Public interest.

This alters the fundamental nature of our understanding of the “Right to Forget” and we have to thank the Kerala Judgement for this clarification.

The principle this establishes is “Right to Forget is not Right to anonymity and the identity can be archived securely in the public interest”.

For example, even when a Court redacts the names of the parties from the copy of the judgement which is published in a data store which is available for Google or Indiakanoon.com to index, within the records of the Court, the Registrar should be able to recognize the parties if required. If the Data Custodian identifies any “Public Interest” in making a voluntary disclosure of the information, there may be fiduciary duty for him to recognize and act accordingly.

For example even in a matrimonial case if the names of parties are held confidential and if there is an instance where one of the parties is a habitual offender and other similar disputes arise indicating the possibility of a criminal intention, then the data custodian may have to consider release of the data to public… may be with the permission of a Court.

Similarly in the Private Sector, if the personal data is held confidential and an incident comes to the knowledge of the company in the public space where there is a link to the data then there may be fiduciary duty  for the data fiduciary to voluntarily submit the data to the relevant authorities even though they are at that time classified as “Archived under Right to Forget Request”.

This disclosure of purpose-expired or Right to forget data in the case of deceased data principals where there may be a legitimate interest of the legal heirs (where there is no nomination) needs to be specifically addressed. Also whether Right to forget data is part of the nominee’s right also remains in need of further debate.

(These views of Naavi are subject to challenge and debate)

(… to be continued)

Naavi

All articles in the series:

Hats off to the Kerala Judgement on Right to Forget-5: Evolution of the Right to be forgotten
Hats off to the Kerala Judgement on Right to Forget-4: Need for Transparency in Judiciary
Hats off to the Kerala Judgement on Right to Forget-3: Right to Forget is not Right to Anonymity..
Hats off to the Kerala Judgement on Right to Forget..2: Ratio Decidendi in Puttaswamy Judgement
Hats off to Kerala High Court for it’s treatise on Right to Forget

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Hats off to the Kerala Judgement on Right to Forget..2: Ratio Decidendi in Puttaswamy Judgement

[This is a continuation of our earlier article on the Kerala Judgement on Right to Forget]

The essential part of the legal point considered by the bench in this case was “Whether in certain cases such as the matrimonial disputes, a party to that proceedings can seek an order to mask his/her name and address and that of the party respondent(s) in the cause title of the judgment and also his/her name and that of the party respondent(s) in the body of the judgment, in order to protect his/her right to privacy, described as the ‘right to be let alone’.

Did Puttawaamy Judgement rule on Right to Forget?

In some of the underlying judgements referred to in this order an argument had been raised that in the Puttaswamy Judgement (Justice K.S.Puttaswamy (Retd) and another v. Union of India and Others [(2017) 10 SCC 1]), it is held that “Right to Privacy” includes the “Right to be forgotten” and hence the petitioner is entitled to the protection of his fundamental right to privacy and has a right to erase contents that are unnecessary, irrelevant, inadequate or no longer relevant.

This contention also requires to be looked at from the point of view of whether Puttaswamy judgement has any precendence value in respect of the “Right to be forgotten being part of the Right to Privacy” since this was not part of the order. Hence whether this is part of the “Ratio Decidendi” or not remains a debatable issue. (PS: Refer this article for more on Article 141 operation).

It is an admitted principle that “Orbiter Dicta” does not have the force of precedence under Article 141 and hence it is important to understand in Puttaswamy judgement what is the ratio decidendi and what is orbiter dicta.

Ratio-Decidendi’ is the determining point which becomes the base for a judgement. On the other hand   obiter-dictum’ connotes a judge’s expression of opinion uttered in court or giving judgement, but not essential to the decision and therefore without binding authority.

The obiter dictum may be termed as a casual remark of the court while deciding the actual issues, which is considered as beyond the ambit of the operative part of the judgement.

In the Puttaswamy judgement, “Whether Right to Forget is part of Right to Privacy” cannot be considered as “Ratio decidendi”  while in the subject Kerala Judgement it is the main issue that was considered and adjudicated. Hence this point is ratio decidendi for this case and not for Puttaswamy case.

…To Be Continued

Naavi

All articles in the series:

Hats off to the Kerala Judgement on Right to Forget-5: Evolution of the Right to be forgotten
Hats off to the Kerala Judgement on Right to Forget-4: Need for Transparency in Judiciary
Hats off to the Kerala Judgement on Right to Forget-3: Right to Forget is not Right to Anonymity..
Hats off to the Kerala Judgement on Right to Forget..2: Ratio Decidendi in Puttaswamy Judgement
Hats off to Kerala High Court for it’s treatise on Right to Forget

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Hats off to Kerala High Court for it’s treatise on Right to Forget

A truly remarkable piece of Judgement has emanated from the Kerala High Court on 22nd December 2022 from the bench of Honourable Justices A Muhamed Mustaque and Shoba Annamma Eapen regarding “Right to Forget”.

The 138 page judgement is worth studying like a text book on understanding several aspects surrounding the issue. The coverage within the judgement exhibits a deep understanding of the international scenario on Privacy and provisions of GDPR.

I will try to provide a gist of the Judgement which is my first impression on the learnings that we can take out of this judgement and leave it for further detailed discussion some time later.

The judgement is a common judgement for 9 different  writ petitions (26500/2020, 6687/2017, 20387/2018, 7642/2020, 8174/2020, 21917/2020, 2604/2021, 12699/2021 & 29448/2021 ) some of which are from those whose names have appeared in Criminal cases and some of which are from those whose names have appeared in Family Court cases.

The final findings are as follows.

i. We declare that a claim for the protection of personal information based on the right to privacy cannot co-exist in an Open Court justice system.

ii. We hold that right to be forgotten cannot be claimed in current proceedings or in a proceedings of recent origin.

It is for the Legislature to fix grounds for the invocation of such a right.

However, the Court, having regard to the facts and circumstances of the case and duration involved related to a crime or any other litigation, may permit a party to invoke the above rights to de-index and to remove the personal information of the party from search engines.

The Court, in appropriate cases, is also entitled to invoke principles related to the right to erasure to allow a party to erase and delete personal data that is available online.

iii. We declare and hold that in family and matrimonial cases, arising from the Family Court jurisdiction or otherwise and also in other cases where the law does not recognise the Open Court system, the Registry of the Court shall not publish personal information of the parties or shall not allow any form of publication containing the identity of the parties on the website or on any other information system maintained by the Court if the parties to such litigation so insist.

iv. We hold that the Registry of the High Court is bound to publish privacy notices on its website in both English and Vernacular languages.

The Court also stated the  following in respect of the writ petitions on hand.

(i). W.P. (C) No. 26500 of 2020:

The petitioner was involved in a crime. Thereafter, based on an order of this Court, the criminal complaint was quashed as the de facto complainant raised no objection. We are of the view that this is not a case where the petitioner can invoke the right to be forgotten to delete past records.

We, therefore, decline the prayer and dismiss the petition.

(ii). W.P. (C) No. 21917 of 2020:

The petitioner was involved in a crime. His grievance for removal from the digital domain of his involvement in a criminal case and of a bail order obtained by him cannot be acceded to.

The writ petition is, therefore, dismissed.

(iii). W.P. (C) No. 8174 of 2020:

The matter pertains to a habeas corpus petition. The petitioner approached this Court alleging the detention of her daughter.

We do not find any reason to hold that the personal information shall not be published online. The writ petition fails, and is accordingly, dismissed.

(iv). W.P. (C) No. 6687 of 2017:

The petitioner approached this Court for solemnising marriage under the Special Marriage Act.

Since the matter is related to matrimonial and family affairs, and we have recognised the right to privacy in such matters, we hold that the petitioner is entitled to the relief sought. This Court has already granted interim relief in tune with the final reliefs sought.

We make the interim relief granted absolute.

(v). W.P. (C) No. 7642 of 2020:

The petitioner was involved in a criminal case related to an allegation of rape. This Court had quashed the proceedings against the petitioner and his father.

We are not inclined to grant reliefs sought for removal of the judgment in the public domain.

The writ petition fails and is, accordingly, dismissed.

(vi). W.P. (C) No. 20387 of 2018:

The petitioner was involved in a criminal case and approached this Court for quashing the criminal case. The petitioner and the de facto complainant settled. The criminal case was quashed in the year 2013.

According to us, the petitioner is not entitled to the relief sought. Dismissed.

(vii). W.P. (C) No. 12699 of 2021:

The petitioner approached this Court earlier in a Transfer petition related to a matrimonial case.

The petitioner also approached this Court in regard to a dispute related to passport arising out of a matrimonial dispute. Considering the nature of the dispute involved, and the publication of the judgment in the public domain, we are of the view that a right to privacy would be invaded.

Accordingly, we allow this writ petition and direct Google LLC to de-index the names and also direct the Registry to ensure Indian Kanoon hides the personal information of the parties online.

(viii). W.P. (C) No. 29448 of 2021:

The petitioner was involved in a crime. The petitioner is aggrieved by the publication of the order in bail online. In light of our views, Writ Petition is only to be dismissed. Accordingly dismissed.

(ix). W.P.(C) No. 2604 of 2021:

The petitioner had approached this Court earlier in O.P.(FC).No.64/2019 to obtain custody of the minor child. By publication of the judgment online, the identity and name of the child are revealed.

That being the case, the petitioner is entitled to relief in this case.

There shall be a direction to the additional respondent Google LLC to de-index the judgment in O.P.(FC).No.64/2019 and there shall also be a direction to the Registry to ensure that Indian Kanoon redacts the names and personal information of the parties or removes the publication of the judgment.

The Court also added:

The Registrar of the High Court of Kerala is directed to publish the privacy notice within two months in both English and Malayalam languages on the websites of the High Court and the District Judiciary.

The individual judgements in different petitions reveal the logic behind the Jurisprudence being reflected in this judgement.

We will continue this discussion…. on the detailed content of the Judgement in subsequent articles…

Naavi

All articles in the series:

Hats off to the Kerala Judgement on Right to Forget-5: Evolution of the Right to be forgotten
Hats off to the Kerala Judgement on Right to Forget-4: Need for Transparency in Judiciary
Hats off to the Kerala Judgement on Right to Forget-3: Right to Forget is not Right to Anonymity..
Hats off to the Kerala Judgement on Right to Forget..2: Ratio Decidendi in Puttaswamy Judgement
Hats off to Kerala High Court for it’s treatise on Right to Forget

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ITA 2000 amended to remove Section 66A

Way back in March 2015, the Supreme Court in its judgement said that  Section 66A of ITA 2000/8 as unconstitutional because it curtails Freedom of Speech.  However, the Government had not passed any amendment of law to remove the section. Subsequently, on several instances, some Courts and Police continued to use Section 66A ignoring the Supreme Court observations by ignorance or otherwise.

Now in 2022, Government seems to have decided to formally pass an amendment to remove the Section from ITA 2000/8. Along with it, several other sections of ITA 2000 and many other laws have also been amended to remove select portions with an intention to de-criminalize certain aspects of law considered as minor offences.

For this purpose, the Government has introduced a bill titled Jan Viswas (Amendments of Provisions) Bill 2022

About 42 laws have been amended in this Bill including ITA 2000, Trademark Act, Copyright act, Patent Act, PMLA, Motor Vehicles Act, Payment and Settlements Act etc.

In particular, the following changes have been made in ITA 2000.

(A) In section 2, in sub-section (1), in clause (e), for the long line, the following shall be substituted, namely:—

“the State Government, and in any other case—
(I) relating to relevant provision, or a computer resource, which is controlled by the respective Ministry or Department of the Central Government, such Ministry or Department; or
(II) not covered under sub-clause (I), the Central Government;”.

(B) In section 33, in sub-section (2), for the words “punished with imprisonment which may extend up to six months or a fine which may extend up to ten thousand rupees or with both”, the words “liable to pay penalty which may extend to five lakh rupees” shall be substituted.

(C) In section 44,

(i) in clause (a), for the words “one lakh and fifty thousand”, the words “fifteen lakh” shall be substituted;
(ii) in clause (b), for the words “five thousand”, the words “fifty thousand” shall be substituted;
(iii) in clause (c), for the words “ten thousand”, the words “one lakh” shall be substituted.

(D) In section 45, for the words “compensation not exceeding twenty-five thousand rupees to the person affected by such contravention or a penalty not exceeding twenty-five thousand rupees”, the following shall be substituted, namely:—
“penalty not exceeding one lakh rupees, in addition to compensation to the person affected by such contravention not exceeding—
(a) ten lakh rupees, by an intermediary, company or body corporate; or
(b) one lakh rupees, by any other person.”.

(E) In section 46, in sub-section (1), for the words “under this Chapter”, the words “under this Act” shall be substituted.

(F) Section 66A shall be omitted.

(G) In section 67C, in sub-section (2), for the words “punished with an imprisonment for a term which may extend to three years and also be liable to fine”, the words “liable to pay penalty which may extend to twenty-five lakh rupees”
shall be substituted.

(H) In section 68, in sub-section (2), for the words “on conviction to imprisonment for a term not exceeding two years or a fine not exceeding one lakh rupees or with both”, the words “to pay penalty which may extend to twenty-five lakh
rupees” shall be substituted.

(I) In section 69B, in sub-section (4), for the words “three years and shall also be liable to fine”, the words “one year or shall be liable to fine which may extend to one crore rupees, or with both” shall be substituted.

(J) In section 70B, in sub-section (7), for the words “one lakh”, the words “one crore” shall be substituted.

(K) In section 72, for the words “punished with imprisonment for a term which may extend to two years, or with fine which may extend to one lakh rupees, or with both”, the words “liable to penalty which may extend to five lakh rupees” shall be substituted.

(L) In section 72A, for the words “punished with imprisonment for a term which may extend to three years, or with fine which may extend to five lakh rupees, or with both”, the words “liable to pay penalty which may extend to twenty-five lakh rupees” shall be substituted.

The Changes in the definition of the “Appropriate Government” under Section 2 will apply to state laws enacted under List III of the Seventh schedule of the Constitution and  delegates the responsibility in relevant circumstances to the Ministries and Departments or by default on the Central Government.

The changes are significant since apart from officially removing Section 66A, it has removed the criminal provisions in Section 33, 67C, 68, 72, 72A, and hence these sections under Chapter XI now actually belong to Chapter IX where Civil penalties are covered.

This change would also bring these sections under the powers of the Adjudicator and Section 46 has been amended to state “Under this Act instead of Under this Chapter”.

Section 33 has been amended to increase the penalty from Rs 10000/- to Rs 5 lakhs. (Regarding surrendering of license by a Certifying authority on revocation or suspension)

Section 44 which relates to Certifying Authorities, has been amended to increase the penalties

from Rs 1.5 lakhs to Rs Rs 15 lakhs under clause (a), (not furnishing document  to CCA),  from Rs 5000/- to Rs 50,000/- under clause (b) (not filing returns) and

from Rs 10,000 to Rs one lakh under clause (c). (not maintaining books of account)

Section 45 in which residual penalty of Rs 25000/- had been provided has been modified to increase the penalty to Rs 1 lakh in addition to compensation to the person affected to the extent of Rs 10 lakhs by an Intermediary, Company or a Body Corporate or Rs 1 lakh in other cases.

It has reduced the imprisonment under Section 69A from 3 years to one year making it non cognizable and bailable

The fine under Section 70B is raised to Rs 1 crore from Rs 1 lakh.

Penalty under section 67C is increased to Rs 25 lakhs.

Penalty under Section 68 is increased to Rs 25 lakhs

Penalty under Section 69B is increased to Rs 1 crore

Penalty under Section 72 is increased to Rs 5 lakhs

Penalty under Section 72A is increased to Rs 25 lakhs.

The Bill is presented in the Parliament and is due to be passed. The passage of the Bill is likely to significantly improve the Ease of Doing Business index of the country also. At the same time, the MeitY is also working on a comprehensive modification of ITA 2000 by replacing it with a new Act called Digital India Act.

(P.S: The above changes have been incorporated in the copy of ITA 2000 in several sections of this website and www.ita2008.in )

Naavi

Also Read:

NDTV.com

For easy reference the affected sections of ITA 2000/8 are available here:

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Right to Be Forgotten ..in Matrimonial Cases

Kerala High Court has pronounced a significant judgement in respect of Right to Forget by distinguishing cases where the “Open Court Justice System”  is not recognized and in-camera proceedings are permitted. In matrimonial cases it has ruled that on request the identities of the parties may be masked in the published judgements.

More details in livelaw here.

Copy of the judgement is here

The discussion is relevant since in the new DPDPB 2022 there is no mention of Right to Forget which automatically places it as a right to be exercised only on specific request in a judicial forum.

The Right to Erase which is the closest right  to “Right to Forget” is considered as limited to the removal of personal data from active use which is an obligation on the data fiduciary when the purpose of processing is deemed to have  been completed or the consent has been withdrawn. However “Right to Erase” does not extend to refuse “Disclosure” if the request for disclosure is from an authorized law enforcement agency or is otherwise required in the legitimate interest situation.

In such circumstances, Personal data on expiry of processing would be retained for a reasonable period as per other legislations like the Income Tax act or IPC or ITA 2000 as long as it is legally required. It would have to be however secured and disclosed only under due process.

Some clarification on these thoughts are expected after the new Act becomes a law and until that time we need to keep our fingers crossed and consider the Right to Forget as a grey area under the new Act.

Naavi

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Lifetime Achievement Award from CySi,ExNoRa,and SPIN-Chennai

On 17h December 2022, Cyber Society of India, ExNoRa and SPIN-to Chennai conducted an event in Chennai in which Naavi was conferred a Life Time Achievement Award for his contributions to the Cyber Jurisprudence. Simultaneously three other persons who along with Naavi were instrumental in the first conviction under ITA 2000 which occurred in 2004 namely the Magistrate Sri Arul Raj, The IO, Sri Balu Swaminathan and Special Public prosecutor, Mr Kodandaraman were also facilitated with life time achievement awards.

PROGRAM

The event was held at Hotel Raj Sundar Palace, Raja Annamalai Puram. Several dignitaries including senior advocates participated in the event.

Sitting Judge of Madras High Court, Honourable Sri Bharata Chakravarthy gave away the awards.

Further, Advocate M A Ranganath who argued the Umashankar case in the Madras High Court was also facilitated as a Guest of Honour.

Suhas Katti case was historical because it was the first criminal conviction under ITA 2000 which occurred in the year 2004. It was also the first case in which Section 65B certificate was admitted as an evidence and was the main evidence of the offence. Naavi had presented the evidence. (Copy of the judgement is available here:

Copy of Suhas katti Judgement

Umashankar Vs ICICI Bank adjudication was historic because it was the first instance of Adjudication under ITA 2000 resulting in the liability of the Intermediary Bank was upheld in a Phishing Case. The award was given by the then IT Secretary of Tamil Nadu, Mr P W C Dawidar in 2010.

It was subsequently confirmed by the TDSAT under the chairmanship of Honourable Retired Supreme Court Justice, Sri Shiva Kirti Singh in 2019. (During the intervening period the trial continued in Cyber Appellate Tribunal for 2 years before the Tribunal became dysfunctional and later re-started its activities under TDSAT in 2018).

Further the Bank filed an appeal in Madras High Court and the trial was concluded and Judgement dismissing the appeal was released on November 9, 2022.

Naavi argued the case under a Power of Attorney on behalf of the victim Sri S Umashankar who is an NRI, in Adjudication, Cyber Appellate Tribunal and TDSAT. In Madras High Court he was the Expert to assist the Court and Advocate Ranganath presented the arguments.

The  judgement copies in S Umashankar case are available below:

  1. Adjudication award from Adjudicator of Tamil Nadu
  2. TDSAT Judgement of January 2019 and Reviewed Judgement from TDSAT of March 2019
  3. AO’s order following TDSAT Review
  4. Madras High Court order on Naavi as PIP
  5. Judgment of Madras High Court.

Naavi

Also read:

Magistrate D Arul Raj is an unsung hero in development of Jurisprudence under Section 65B of Indian Evidence Act : December 9, 2017

Also view the Discussion on the case at FDPPI

Some videos I found on Youtube :

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