Neutral Citation Number: 2023:DHC:2806 cast any mandatory obligation upon an SSMI to deploy automated tools and only an endeavour is to be made towards adopting any measures. f. Application of tools to remove content has been discussed by the Supreme Court in In Re: Prajwala Letter dated 18.02.2015 Videos of Sexual Violence and Recommendations, S.M.W. (Crl.) No. 3 of 2015, but this has been limited to Child Sexual Abuse Material (CSAM). India has entered into an Memorandum of Understanding (MoU) with the National Centre for Missing and Exploited Children (NCMEC) for effectively combating the menace of CSAM content with reports being sent to the National Crime Records Bureau (NCRB) and the Ministry of Home Affairs. For the purposes of preventing CSAM content, automated flagging through hash-matching and Artificial Intelligence (AI)-based tools enables Google to act quickly and accurately to enforce its policies and rules. However, while cognition by an AI/ML (Artificial Intelligence/Machine Learning) tool of an image on the theme of “explicit content with a child subject” is useful to combat CSAM, a similar determination of “explicit content with an adult female subject” may not prove to be useful in any manner in identifying NCII. The factor of “consent” which is an essential ingredient for categorization of NCII cannot be detected by automated tools. g. Other automated tools such as pattern recognition or AV matching are deployed for limited purposes and, thus, they cannot be applied indiscriminately to content of third-parties on any other Signature Not Verified Digitally Signed By:SHAZAAD ZAKIR Signing Date:26.04.2023 17:19:50 W.P.(CRL) 1505/2021 Page 51 of 88