29 targeted subject, and the individual is never notified that an interception/access took place, even after the close of the investigation. Furthermore, the regime is silent on certain categories of data – such as location data. The differences between the regimes, and the policy gaps that exist, facilitate violations of privacy as broad interception/access is permitted to a wide category of information, during vague and changing circumstances, without adequate safeguards in place.” This Hon’ble Court in Puttaswamy (Privacy) has endorsed the recommendations made by the Group of Experts. True Copy of the Justice A. P. Shah Report dated 16.10.2012 is annexed herewith as ANNEXURE P-12 (Page Nos. 142 to 216). 32. The absence of judicial mind, ex-ante or post facto, for carrying out electronic surveillance has been universally deprecated across developed and developing democracies. The “International Principles on the Application of Human Rights to Communication Surveillance” [“Necessary and Proportionate Principles”], prepared by a coalition of Privacy Experts and Organisations, launched at the U.N. Human Rights Council in Geneva in 2013, has pithily encapsulated the principle in the following words: “Principle 6: Competent judicial authority Determinations related to Communications Surveillance must be made by a competent judicial authority that is impartial and independent. The authority must be: (i) separate and independent from the authorities conducting Communications Surveillance; (ii) conversant in issues related to and competent to make judicial decisions about the legality of