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Will The Digital Gaze Set Privacy Ablaze? A Post Puttaswamy Analysis Of The National Automated Facial Recognition System (NAFRS) In Light Of Article 21




Dhriti Mahajan (LL.M.), University School of Law and Legal Studies, Guru Gobind Singh Indraprastha University


ABSTRACT


The paper critically examines India’s National Automated Facial Recognition System (NAFRS) as a constitutional, ethical, and legal dilemma within the post- Puttaswamy privacy framework. It analyzes how the government’s move toward biometric surveillance challenges Article 21’s guarantees of dignity and autonomy by operating without explicit legislative sanction, judicial oversight, or procedural safeguards. Through doctrinal and comparative analysis, the study evaluates NAFRS against the threefold test of legality, necessity, and proportionality, revealing its failure to meet constitutional standards. Drawing parallels with the EU’s GDPR, the UK’s Surveillance Camera Code, the US’s judicial safeguards, and China’s authoritarian model, the paper underscores India’s institutional gaps and the risk of mass surveillance becoming normalized. It argues that unchecked technological governance undermines democratic citizenship and informational self-determination. Finally, it proposes a rights-based biometric governance framework emphasizing judicial authorization, independent oversight, privacy-by- design, and legislative accountability. The study concludes that protecting the “right to be left alone” is central to maintaining constitutional morality and preventing India from drifting toward a surveillance state.


Keywords: Facial Recognition Technology; Right to Privacy; Constitutional Morality; Surveillance State; Puttaswamy Judgment; Article 21; Digital Governance; Data Protection; Proportionality Test; NAFRS.



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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