44 conduct of surveillance, especially in the need for judicial oversight. Giving the examples of Germany, U.K., and South Africa, the Committee noted that executive review alone “is not in tandem” with comparative models of democratic nations. Keeping this in mind, the Committee recommended that the Central Government bring in a law that would “provide for both parliamentary oversight as well as judicial approval of all requests for non-consensual access to personal data.” However, no such law exists currently. D. SECTION 69 OF THE SUBSTANTIVELY IT ACT AND THE IT RULES DO FULFIL THE PRINCIPLES NOT OF PROPORTIONALITY XXI. BECAUSE neither Section 69 of the IT Act, nor the 2009 IT Rules have codified the basic principles of necessity and proportionality, as required under the Puttaswamy (Privacy) and the privacy principles elaborated in the Justice A.P. Shah Report. Although Rule 8 requires the competent authority to consider alternative means of acquiring information and ensure that no “other reasonable means” exist to acquire the information, the IT Act and Rules are silent on the proportionality requirement. a. This, in itself, runs against the proportionality standard, since this requires a determination not in respect of whether there is a less onerous means of achieving a particular government objective (covered under Section 69 of the IT Act) but whether there is an alternative way of acquiring the information. There is, therefore, an inherent assumption that the only possible means of achieving a particular objective (e.g. preventing incitement of a cognizable