7 (a) What is the standard for establishing an infringement of fundamental rights, and demonstrating “harm”, in the context of State-enabled surveillance, which, by its very definition, involves a modicum of secrecy? (b) Whether the standards laid down in the Wiretapping Judgment (supra) require to be updated in view of the proliferation of electronic and digital surveillance, in the modern world? (c) Whether the existing legal regime under the IT Act, the 2009 IT Rules, and the impugned Notification, especially the lack of procedural safeguards and the overbroad nature of the provisions, conforms with the principle of proportionality, set out in Puttaswamy (Privacy) and Puttaswamy (Aadhaar)? 5. To best of our knowledge, there is no other Petition, either pending or disposed off, that has been filed before this Hon’ble Court or any other court challenging the constitutional validity of Section 69 of the IT Act and 2009 IT Rules. The Impugned Notification dated 20.12.2018 (bearing No. 14/07/2011-T) is already under challenge before this Hon’ble Court in W.P.(C) No. 02 of 2019 (Amit Sahni v. Union of India). I. DESCRIPTION OF PARTIES 6. IFF, Petitioner No. 1 herein, is a registered under the provisions of Indian Trust Act, 1882 (bearing IN-DL44196137899619O). IFF is represented through its Chairman, Mr. Raman Jit Singh Chima, and is authorized to file the present Petition by virtue of the Resolution dated August 29, 2018. Voluntary contributions received by the Petitioner-Trust are exempt from levy of income

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