AN ANALYSIS INTO THE VIRES OF THE NEW IT RULES OF INDIA

 

IT RULES 2021

-MANVI MOUDGIL[1]

 

ABSTRACT

In the year 1995, internet services were launched in India, with its limited usage, restricted to educational and research purposes. Then in the late 90’s, Indian railway reservation was linked to internet. In the year 2000, cable internet arrived in India[2]. The same year, IT act was introduced. At that time, the term Information Technology was limited to electronic documents, e-signature and digital authentication of records. Social networking sites came to India in the year 2005 and smartphones arrived around the year 2008. Year after year, technology became more advanced and in 2014, 4G network was introduced in India. Since the last decade, internet access at home has substantially increased in India whereas the average cost of mobile data has decreased in the previous years. As the mobile technology developed, along with low-cost internet, India has seen a sharp rise in its user base. While we all know that internet is a great source of information, but at the same time, it is a place of great vulnerability. Keeping in mind this aspect, the Government of India has passed new rules under the section 69 A (2)[3], section 79 (2)(c) [4]and section 87 [5]of the IT act 2000

 

INTRODUCTION

The Information Technology ((Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021[6], have emanated from section 87 of The Information Technology Act 2000, the primary law, which was concerned with cybercrime and electronic commerce in India. IT Rules 2011 and 2021 are the subordinate legislations to the IT act 2000. IT Rules 2021 have replaced the IT rules formed in 2011[7]. These rules were notified on 21st February, 2021 and came into effect on 26th May, 2021. 3 months’ time was given to these social media platforms to comply with these rules. The newly formed rules are a combination of the draft Intermediaries Rules, 2018 and Code of Ethics for Digital Media and OTT Regulation. These rules were formulated by the centre with the help of Ministry of Electronics and Information Technology and Ministry of Information and Broadcasting. According to the centre, the rules established a self-regulatory architecture, Code of Ethics and a three-tier grievance redressal mechanism for social media, OTT platforms and news publishers. Norms of journalistic conduct of the Press Council of India and the Programme Code under the Cable Television Networks Regulation Act, would be required to be observed by the publishers of news on digital media platforms. Therefore, it will provide a level playing field between the offline and digital media. While, Amit khare, secretary, Ministry of information and broadcasting, called the rules “progressive institutional mechanism”, it also faced wrath from media houses, digital platforms and experts, calling the new rules “vague, overbroad and unconstitutionally arbitrary”. Many petitions were filed citing the rules as unconstitutional burdens that impede the freedom of press.

WHAT ARE THEIT RULES 2021?

The new rules broadly deal with the regulation of social media and over the top (OTT) platforms. Social media companies with equal to or more than 50 lakh or 5 million user base come under the ambit of significant social media intermediaries while those with less than 50 lakh or 5 million user base are social media intermediaries. The term intermediary acts as a link between people. Likewise, social media has been referred as intermediary because it helps people connect with each other and acts as a link between them. An intermediary also enables online interaction between two or more users and allow them to create, upload, share, disseminate, modify or access information using its services[8].  Social media intermediaries will be required to follow due diligence or else they will lose their immunity under the safe harbor provisions, defined under section 79 of the IT Act. This also makes the social media platforms liable for posting such content, making them criminally liable for legal prosecution, if they don’t carefully monitor what is being posted online on their platform. Under the new rules, a grievance officer [9]shall be appointed, who will act as a mediator between the govt of India and social media companies. The appointed officer shall acknowledge any complaint received from the government within 24 hrs. and resolve it within 15 days from its receipt. The social media intermediaries shall also appoint chief compliance officer[10], nodal contact[11] person and a resident grievance officer, all of whom shall be residing in India. GOI also told them to publish monthly compliance report.

The significant social media intermediaries are bound to give the information of the first originator to the Indian Law Enforcement agencies, in case the content[12]:

(i) affects the sovereignty and integrity of India;

(ii) threatens, endangers or jeopardizes the security of the State;

(iii) is detrimental to India’s friendly relations with foreign countries;

(iv) is likely to incite violence or disturb the maintenance of public order.

(v) is linked to any kind of offence in relation with rape, sexually explicit material or child sexual abuse material.

An intermediary will be required to remove the above-mentioned content if they get a direct order by any court or a notified government agency.

On the other hand, OTT platforms were required to self-classify the contents under 5 age-based categories,[13]implement parental locks and display the classification rating on every content.

GOI also mentioned that publishers of news on digital media would be required to observe Norms of Journalistic Conduct of the Press Council of India and the Programme Code under the Cable Television Networks Regulation Act. A three-level grievance redressal mechanism[14] has been established under the rules with different levels of self- regulation.

-          Level-I: Self- regulation by the publishers;

-          Level II: Self-regulation by the self-regulating bodies of the publishers;

-          Level III: Oversight mechanism.

 

AFTERMATH AND CRITICS

According to some experts, after the imposition of the new rules, the tax liability of these social media platforms has increased due to which, many small innovative platforms will be discouraged to continue in India. The data retention[15] period has been extended to 6 months, which is claimed to be a big issue for data protection of the users. Although the government claims that its not interested in the content of the messages, the structure of the IT rules suggest otherwise. Certain loopholes have been identified in the guidelines, that can be a great obstacle for the companies as well as people. The provision of identifying the first originator of the message would override end-to-end encryption policy [16]of many social media intermediaries. This can also be misused against any person. Due to these rules, people will be reluctant to express their views, which will ultimately restrict the free flow of information and will deprive them of their fundamental right of freedom of speech and expression. Part III, titled ‘Code of Ethics and Procedure and safeguards in Digital Media’, created an oversight mechanism, which gave the government, unbridled, unfettered and excessive powers to regulate content of digital news platforms. It also bought the publishers of news and content on digital platforms, under the ambit of the government, which will create fear among the people and will affect their independent views and opinions. The newly formed rules gave complete control of OTT platforms, social media and digital news in the hands of the government by providing them with wide discretionary powers, which can be misused by the parties for their political motives. According to the IT rules, the government can ask to remove any content which it thinks is unacceptable. This gives them the power to scrap down and manipulate any information which is disadvantageous to its policies[17].

 

Immediately after the publication of the rules, a number of petitions were filed by numerous social media companies and digital news platforms. Intermediaries were given 3 months to comply with the rules. On the last date, i.e., 25 May 2021, WhatsApp filed a case against the GOI over the rules, arguing that the traceability provision is unconstitutional and against people’s fundamental right to privacy[18]. Twitter also missed the three-month deadline[19] and faced a strong rebuke from the Delhi High Court. It refused to comply with the new rules and claimed a safe harbor protection from any criminal liability in India. In July, Press Trust of India challenged the rules in the High Court of Delhi. Its plea stated that the rules would “usher in an era of surveillance and fear, thereby resulting in self-censorship, which results in abridgement/violation of Fundamental Rights as enshrined under Part III of the constitution of India”.[20]

 

CONCLUSION

Right to Freedom of speech and expression were laid down in the constitution of India for people to put forth their opinion and provide them the right to express their grievances, but the new rules seem to have taken the very rights from the people of the country. It is to be noted that these rules came when there is not even a robust data protection law existing in our country. People today, look for platforms that can bring out the truth and provide them with right information. There must be regulations for the publication of content, but attacking on public’s privacy and giving complete power to the government to remove any content, is completely unacceptable. It is a violation of the fundamental right of free speech and expression. However, the real issues, limited by the present rules go far beyond the regime. These rules can adversely affect the growth of the society. Correct changes must be made to it in order to promote development and progress of the nation.  These rules have been bought into force at a time when people are being slapped with charges under UAPA or prosecuted for sedition for expressing dissent from the government. Therefore, these rules, which would ordinarily seem to be bringing order, are now seen with a lens of suspicion[21]. These regulations can be used by the government to go after individuals who express opinions which are contrary to its interests. While the rules may assist the agencies in going after something that has been deemed as offensive and anti-national, it can also empower these agencies to take down anything that goes against the interests of the government. Therefore, the utmost importance must be given to bring a robust data protection law in the country so that the free flow of expression and ideas is not hindered and people are not threatened by its government for expressing their opinion.

 

REFERENCE

1.     https://www.thebetterindia.com/138354/tripura-cm-mahabharat-internet-history-india/

2.     https://www.indiacode.nic.in/bitstream/123456789/1999/3/A2000-21.pdf

3.     https://www.meity.gov.in/writereaddata/files/Intermediary_Guidelines_and_Digital_Media_Ethics_Code_Rules-2021.pdf

4.     https://www.meity.gov.in/writereaddata/files/GSR314E_10511%281%29_0.pdf

5.     https://www.barandbench.com/columns/the-information-technology-rules-2021-an-assault-on-privacy-as-we-know-it

6.     https://lexlife.in/2021/05/06/an-extensive-critical-analysis-of-draft-it-rules-2021/

7.     https://blog.forumias.com/critical-analysis-of-new-it-rules-2021/

8.     https://www.firstpost.com/tech/news-analysis/it-rules-2021-add-to-fears-over-online-speech-privacy-critics-believe-it-may-lead-to-outright-censorship-9810571.html

9.     https://www.newslaundry.com/2021/07/05/the-leaflet-moves-high-court-against-vague-overbroad-unconstitutionally-arbitrary-it-rules

10.  https://www.news18.com/news/tech/it-rules-2021-explained-rules-facebook-twitter-koo-whatsapp-and-social-media-apps-must-follow-3777329.html

11.  https://blog.ipleaders.in/rules-2021-impact-blanket-privacy/

12.  https://www.firstpost.com/india/it-rules-2021-explained-non-compliance-will-expose-whatsapp-facebook-twitter-to-significant-liability-9661461.html

13.  https://indianexpress.com/article/technology/tech-news-technology/whatsapp-vs-indian-government-over-new-social-media-rules-7-points-to-note-7332708/

14.  https://thewire.in/tech/explainer-how-the-new-it-rules-take-away-our-digital-rights

15.  https://scroll.in/latest/999701/news-broadcasters-association-challenges-new-it-rules-in-kerala-high-court

 

 



[1]. 3rd year, B.A.L.L.B, Punjab School of Law, Punjabi University, (Patiala), manvimoudgil28@gmail.com

[3]. Information Technology Act, 2000, chapter XI, ‘Offences’, [section 69 A (2)], 2000, (India)

[4]. Information Technology Act, 2000, chapter XII, ‘Intermediaries not to be liable in certain cases’, [section 79 (2) (c)], 2000, (India)

[5]. Information Technology Act, 2000, chapter XIII, ‘Miscellaneous’, (section 87), 2000, (India)

[6]. Information Technology Rules, 2021, notified by Ministry of Electronics and Information Technology, New Delhi, the 25th February, 2021. Conferred by sub-section (1), clauses (z) and (zg) of sub-section (2) of section 87 of the Information Technology Act, 2000 (21 of 2000), and in supersession of the Information Technology (Intermediaries Guidelines) Rules, 2011, (India)

[7]. Information Technology Rules, 2011, — Conferred by clause (zg) of subsection (2) of section 87 read with sub-section (2) of section 79 of the Information Technology Act, 2000 (21 of 2000), the Central Government, 2000, (India)

[10]. IT rules, 2021, [section 4(a)], 2021, (India)

[11]. IT rules, 2021, [section 4(b)], 2021, (India)

[13].  Code of Ethics, II (B) (i), IT rules, 2021, (India)

[14]. Section 9 (3), IT rules, 2021, (India)

[15]. I-pleaders, https://blog.ipleaders.in/rules-2021-impact-blanket-privacy/, (last visited 17 July, 2021)

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