National Level Public Policy Document: Commentary on the Draft Digital Personal Data Protection Rules, 2025

Abstract

This commentary, authored by Prof. (Dr.) Shilohu Rao, with the help of student contributions (attributed on page no.2) at the Centre for Law and Technology at National Law University, Jodhpur, provides a meticulous evaluation of the Draft Digital Personal Data Protection Rules, 2025. Employing a robust methodology that integrates expert surveys and a legal evaluation matrix, the document assesses each rule against foundational principles drawn from seminal legal sources, including the Puttaswamy judgment, the Srikrishna Committee Report, Law Commission Reports, and the Joint Parliamentary Committee Report on the Data Protection Bill, 2019. Rules are scored on a 1-to-7 scale, with results ranging from 3 to 5.5, reflecting moderate to good compliance but underscoring notable shortcomings. Key issues identified include vague definitions, insufficient accessibility provisions, and weak safeguards for state data processing. The commentary offers precise, rule-specific recommendations to enhance clarity, inclusivity, and alignment with global standards. Central to the analysis, the legal evaluation matrix ensures a systematic and principled review, making this document a critical resource for policymakers seeking to strengthen India’s data protection framework.