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Under The Algorithmic Eye: Evaluating AI- Driven Surveillance And The Digital Personal Data Protection Act, 2023




Amardeep, PhD Research Scholar, Rajiv Gandhi National University of Law, Patiala


ABSTRACT


The Digital Personal Data Protection Act, 2023 is commonly presented as the statute that gives effect to the right to informational privacy recognised in Justice K.S. Puttaswamy v. Union of India. This article tests that presentation against a practice the Act is poorly equipped to govern, namely the use of artificial intelligence by police and administrative agencies to identify and track individuals in public space. The Act is built for consent based collection by private fiduciaries. Algorithmic surveillance does not work that way. Data is captured without any act of provision by the individual, and the injury it produces is an injury of inference. Section 17(2) (a), which permits the Central Government to exempt any instrumentality of the State from the whole of the Act by a simple notification, then turns that gap into a permission. Reading the exemption power together with Sections 7 and 36 of the Act, Rule 23 of the Digital Personal Data Protection Rules, 2025, and the amendment of Section 8(1)(j) of the Right to Information Act, 2005, the article argues that the framework fails the legality limb of the proportionality standard well before any question of necessity or balancing is reached. A reform agenda follows, drawing on the European Union's Artificial Intelligence Act and on R (Bridges) v. Chief Constable of South Wales Police.


Keywords: informational privacy; facial recognition; Digital Personal Data Protection Act, 2023; proportionality; algorithmic accountability; state surveillance.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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