53 not extend to an entire (religious/geographic etc.) section of the population. In this respect, it is respectfully submitted that, in Puttaswamy (Privacy), it is made clear that bulk or “mass” surveillance is ruled out under the proportionality standard. In paragraph 70, while referring to the PUCL (Wiretapping) judgment, Chandrachud J. observed that: “The requirements also mandate describing the nature and location of the facilities from which the communication is to be intercepted, the nature of the communication and the identity of the person, if it is known.” XXXVII. BECAUSE this Hon’ble Court in A.K. Roy v Union of India, (1982) 1 SCC 271, a similarly broad expression “supplies and services essential to the life of the community” - was struck down for over-breadth, in the absence of specific enumeration of the good and supplies. XXXVIII. BECAUSE apart from the above restriction on any person or class of persons, there are no restrictions on the interception, decryption, monitoring or disclosure of information by executive officers, done without any targeting. H. XXXIX. THE IMPUGNED NOTIFICATION IS UNCONSTITUTIONAL BECAUSE the security and intelligence agencies that have been notified and authorised under the impugned notification to carry out the interception, monitoring and decryption activities, particularly the Intelligence Bureau, Central Bureau of Investigation, and the Cabinet Secretariat (Research & Analysis Wing) lack a statutory basis, and are therefore hit by the Puttaswamy standard. It

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