30 Communications Surveillance, the technologies used and human rights; and (iii) have adequate resources in exercising the functions assigned to them.” Justice Nariman in Puttaswamy (Privacy) (concurring) has recognised the importance of the above international development for securing, protecting and interpreting the scope of right to privacy in India. True Copy of the ‘International Principles on the Application of Human Rights to Communications Surveillance’ (May 2014) is annexed herewith as ANNEXURE P-13 (Page Nos. 217 to 231). 33. More recently, the ‘Committee of Experts’ constituted in 2017 under the Chairmanship of Justice B. N. Srikrishna highlighted the importance of transparency, due process, and proportionality in the conduct of surveillance, especially in their manifestation of judicial oversight, in the following manner: “Surveillance should not be carried out without a degree of transparency that can pass the muster of the Puttaswamy test of necessity, proportionality and due process. This can take various forms, including information provided to the public, legislative oversight, executive and administrative oversight and judicial oversight. This would ensure scrutiny over the working of such agencies and infuse public accountability. Executive review alone is not in tandem with comparative models in democratic nations which either provide for legislative oversight, judicial approval or both.” The Committee went on to give the examples of Germany (where legislative oversight exists), U.K. (where judicial review exists), and South Africa (where some form of both exist) and pointed out that the data protection legislations in these countries