12 fide in public interest for the benefit of Internet users and citizens of India. Since these persons are numerous, and unaware of directions given to conduct electronic surveillance of their communications under the impugned provisions, given the inherently secret nature of surveillance, they are unlikely to approach this Hon’ble Court. There is no civil, criminal or revenue litigation, involving the Petitioners, that is pending or decided in relation to issues raised in the present Writ Petition. 13. The Petitioners have not made any representation to the Respondents thus far, in view of the urgency involved and grave violation of fundamental rights. The Petition is based on authentic information and other public documents sourced from the Respondents. The Petitioners have means to pay costs, if any, imposed by the Hon’ble Court and on an undertaking to the Hon’ble Court in that respect. 14. Union of India, Respondent No. 1 herein, is represented through the Secretary of Department of Legal Affairs under the Ministry of Law & Justice in accordance with the Government of India (Allocation of Business) Rules, 1961. The Ministry of Law & Justice is responsible for defending cases relating to the constitutional validity of central legislations and rules before this Hon’ble Court. 15. Ministry of Home Affairs, under the Central Government, is Respondent No. 2 herein, and is represented through the Home Secretary, who is the designated ‘Competent Authority’ by virtue of Rule 2(d)(i) of the 2009 IT Rules and is responsible for authorising directions for electronic surveillance under Section 69(1) read with Rule 3 of the 2009 IT Rules.

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