3 (Procedure for Safeguards for Interception, Monitoring and Decryption of Information) Rules, 2009 is annexed herewith as ANNEXURE P-1 (Page Nos. 69 to 83). True Copy of the Notification dated 20.12.2018 (bearing No. 14/07/2011-T) issued by the Ministry of Home Affairs is annexed herewith as ANNEXURE P-2 (Page No. 84). 2. Internet Freedom Foundation [“IFF”], Petitioner No. 1 herein, is a registered charitable Trust, setup inter alia to protect, promote and defend human rights of citizens using information communication technologies [“ICT”]. The Petitioner-Trust is deeply concerned by the pervasive, sweeping, and clandestine activities of the State to intercept, monitor, and decrypt communications and other data generated, stored, shared, or transmitted through digital platforms. The existing legal regime governing electronic surveillance, specifically through the IT Act and Rules thereunder, have undermined the freedom of speech and expression of Internet users, and have adversely impacted the right to privacy of citizens. To this end, the Petitioners humbly state that the said provisions enabling electronic surveillance are illegal and unconstitutional, inter alia, for the following reasons: A. Section 69 of the IT Act, impugned herein, gives overbroad, sweeping, and arbitrary powers to the State to conduct covert electronic surveillance by intercepting, monitoring, and decrypting digital communications. The very existence of such surveillance apparatus and authority with the State, regardless of its actual use, infringes fundamental rights under Articles 19(1)(a) and 21 of the Constitution. Surveillance impacts the right to privacy, especially “intellectual privacy” (the freedom to read and debate without being monitored). It chills the exercise of