Abstract

In this digital age, Right to Privacy is a fundamental right which is being acknowledge by different jurisdiction in this world. This research paper deals with a comparative study of right to privacy in India as compared with United Kingdom, concentrating their respective legal frameworks, their major judicial interpretations and examines their differences form a cyber law perspective. The right to privacy in India is elaborated in the landmark Supreme Court judgement “Justice K.S Puttaswamy (Retd.) vs. Union of India (2017)”, which declared privacy as a constitutional right under Article 21 of the Constitution of India. This landmark judgement has generated the legislative and judicial reforms that focuses on protection of personal data in cyberspace. To elaborating modern digital privacy concern, key statutes like Information Technology Act, 2000 and the Personal Data Protection Bill, 2019 are scrutinize to understand their effects and limitations. To the contrary, the United Kingdom has a deep-rooted privacy law, named as Human Rights Act, 1998 and further reinforce by the General Data Protection Regulation (GDPR) post-Brexit through the Data Protection Act, 2018. The U. K’s privacy framework is elaborated by rigorous data protection standards and strong enforcement mechanisms, considers its commitment to validate privacy rights. This research paper examines the judicial interpretations and legislative measures of both the countries, that elaborates their strengths and weaknesses. It also defines how cultural, historical and political contexts impacts these legal landscapes. Under this paper the comparative analysis, focuses on to provides understanding of the effectiveness of the privacy protection in this digital age. Giving suggestion and recommendations towards synchronizing cyber laws at global level, also to elaborate the challenges raised by rapid technological advancements.

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