GENERAL/ MISCELLANEOUS CIRCULARS

Analysis of Proportionality Test in Digital Personal Data Protection Act by Subhashis Banerjee

By TEAM CIRCULAR EXPRESS • 05 Nov 2026
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• This article by Subhashis Banerjee examines the Digital Personal Data Protection Act, 2023, arguing it fails the proportionality test established in the Puttaswamy judgment.
• It highlights that the Act relies on consent rather than independent constitutional scrutiny.
• The author advocates for mandatory, published proportionality analyses before deploying intrusive state data processing systems to ensure rights protection.
purpose of issuance
Critique of the DPDP Act 2023 regarding the lack of a proportionality test
is it guidelines or office order
Article/Analysis
pertains to school or college or teachers or cbse or other
Not applicable
Name of Officer
Subhashis Banerjee
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