UPSC MainsLAW-PAPER-I201910 Marks150 Words
Q5.

“Right to Privacy is protected as an intrinsic part of life and personal liberty enshrined under Article 21 of the Constitution of India.” Elucidate this statement in the light of the decision of Justice K.S. Puttaswamy (Retd.) v. Union of India.

How to Approach

This question requires a nuanced understanding of the Right to Privacy and its evolution in Indian law. The approach should begin by briefly defining the right to privacy and its historical context. Then, elaborate on the Puttaswamy judgment, highlighting its key findings and reasoning. Finally, explain how the judgment established privacy as an intrinsic part of Article 21, linking it to life and personal liberty. Structure the answer thematically, focusing on the legal reasoning and implications of the judgment.

Model Answer

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Introduction

The Right to Privacy is a fundamental human right, encompassing an individual’s autonomy to make decisions about their personal information and bodily integrity without undue interference. Historically, Indian courts grappled with whether such a right was explicitly enshrined in the Constitution. The landmark judgment in *Justice K.S. Puttaswamy (Retd.) v. Union of India* (2017) decisively resolved this ambiguity. This case challenged the constitutional validity of Aadhaar, India’s biometric identification system, and fundamentally altered the landscape of privacy rights in India. It affirmed that privacy is a constitutionally protected right, intrinsically linked to life and personal liberty.

Historical Context & Pre-Puttaswamy Era

Prior to 2017, Indian courts had taken differing views on the right to privacy. The conflicting rulings in *Kesavananda Bharati v. State of Kerala* (1973) and *Maneka Gandhi v. Union of India* (1978) created uncertainty. While *Kesavananda Bharati* suggested a right to privacy, *Maneka Gandhi* seemed to limit it. The absence of explicit mention in the Constitution led to a lack of clarity and inconsistent application.

The Puttaswamy Judgment: A Watershed Moment

The *Puttaswamy* case involved a challenge to the Aadhaar scheme, arguing it violated the right to privacy. A nine-judge bench of the Supreme Court unanimously ruled that the right to privacy is a fundamental right protected under Article 21 of the Constitution. The court drew upon constitutional history, comparative jurisprudence (specifically, the US Bill of Rights and European Convention on Human Rights), and the concept of human dignity to reach this conclusion.

Reasoning and Key Findings

  • Intrinsic Link to Article 21: The Court held that the right to privacy is an "essential and inextricable facet" of the right to life and personal liberty guaranteed by Article 21. Without privacy, individual autonomy and dignity are undermined.
  • Constitutional History: The judgment emphasized the Constituent Assembly's intent to guarantee fundamental freedoms, implying a right to privacy even if not explicitly stated.
  • Human Dignity: The Court recognized that privacy is crucial for maintaining human dignity and allowing individuals to flourish.
  • Reasonable Expectation of Privacy: The judgment reaffirmed the concept of a "reasonable expectation of privacy," acknowledging that not all information is private.

Implications and Subsequent Developments

The *Puttaswamy* judgment has far-reaching implications for various aspects of Indian law and policy:

  • Data Protection: It spurred discussions and efforts to develop a comprehensive data protection framework. The Personal Data Protection Bill (later withdrawn and replaced with the Digital Personal Data Protection Act, 2023) is a direct consequence of this judgment.
  • Surveillance and Technology: The judgment necessitates stricter scrutiny of government surveillance programs and the use of technology that impacts privacy.
  • Aadhaar Scheme: While upholding the Aadhaar Act, the Court imposed limitations, including the right to opt-out and restrictions on data sharing.
  • Freedom of Expression: The right to privacy also impacts freedom of expression, as it protects the ability to communicate and receive information freely.

Balancing Privacy with Public Interest

The Court acknowledged that the right to privacy is not absolute and can be subject to reasonable restrictions in the interests of public order, national security, and the well-being of others. Any such restrictions must be proportionate and necessary.

Aspect Pre-Puttaswamy Post-Puttaswamy
Right to Privacy Unclear, conflicting views Fundamental right under Article 21
Legal Basis Inferred, not explicitly stated Explicitly recognized
Data Protection Limited legal framework Emphasis on comprehensive data protection laws

Conclusion

The *Puttaswamy* judgment represents a monumental shift in Indian constitutional jurisprudence, unequivocally establishing the Right to Privacy as an intrinsic aspect of life and personal liberty under Article 21. This landmark decision has profound implications for individual freedoms, data protection, and the balance between individual rights and the interests of the state. Moving forward, the judiciary and legislature must work collaboratively to ensure that this right is effectively protected and balanced with other constitutional values, particularly in the context of rapidly evolving technologies.

Answer Length

This is a comprehensive model answer for learning purposes and may exceed the word limit. In the exam, always adhere to the prescribed word count.

Additional Resources

Key Definitions

Aadhaar
Aadhaar is a 12-digit unique identification number issued to Indian residents, based on their biometric and demographic data. It serves as proof of identity and address.
Personal Data
Any data relating to an identified or identifiable natural person. This can include names, contact details, location data, and more.

Key Statistics

As of December 2023, over 1.3 billion Indians have enrolled for Aadhaar, covering over 99% of the adult population. (Source: UIDAI website)

Source: UIDAI Website

India ranks 122 out of 180 countries in the 2023 Press Freedom Index, reflecting concerns about government surveillance and restrictions on freedom of expression, areas impacted by the Right to Privacy.

Source: Reporters Without Borders

Examples

Data Breach Incident

The recent data breach involving the leak of Aadhaar data online highlighted the vulnerability of personal information and the need for robust data protection measures, further emphasizing the importance of the *Puttaswamy* principles.

Frequently Asked Questions

Does the Puttaswamy judgment mean there is no restriction on privacy?

No, the judgment clarifies that the right to privacy is not absolute and can be subject to reasonable restrictions in the interests of public order, national security, and the well-being of others.

Topics Covered

PolityConstitutional LawFundamental RightsPrivacyJudicial Interpretation