India's Evolving Cyberlaw Framework: A Comparative Analysis of India’s DPDP Act, EU GDPR, UK Framework and Singapore’s PDPA

  • Unique Paper ID: 208472
  • PageNo: 237-243
  • Abstract:
  • India now runs a large part of its economic and social life through digital systems, and this has meant that huge amounts of personal data move between government bodies, businesses and online platforms every day. At the same time, technologies such as artificial intelligence, cloud computing, the Internet of Things, automated profiling and synthetic media are creating risks that older, narrower cyberlaw provisions were never designed to handle. India deals with these issues with the laws and rules like IT Act 2000, IT Rules 2021, DPDP Act 2023 and the DPDP Rules 2025. The main objective of my paper is to ask the question whether is this framework capable enough to keep up with the new technology or does it need new patches. The paper compares India’s system with the EU GDPR, the UK and Singapore’s PDPA in areas such as privacy rights, consent, data security, breach reporting, cross border data transfers, accountability and enforcement. It finds that India has created a strong legal base for the framework but its success will depend on proper implementation, capable regulators and clear guidance for new emerging technologies. This paper will recommend a new approach to regulations one that is reviewed on regular periods and is backed up by proper implemented guidance. The research will use the results of the gap analysis between these frameworks allowing to identify strength, limitations, weakness to be identified. A simple five-point comparative table is used to identify the differences between these frameworks. These steps can help India develop a stronger and more compatible framework which will support the growth of digital economy

Copyright & License

Copyright © 2026 Authors retain the copyright of this article. This article is an open access article distributed under the Creative Commons Attribution License which permits unrestricted use, distribution, and reproduction in any medium, provided the original work is properly cited.

BibTeX

@article{208472,
        author = {Aditya Jitendra Choudhary and Dr. Swapnesh Taterh},
        title = {India's Evolving Cyberlaw Framework: A Comparative Analysis of India’s DPDP Act, EU GDPR, UK Framework and Singapore’s PDPA},
        journal = {International Journal of Innovative Research in Technology},
        year = {2026},
        volume = {13},
        number = {no},
        pages = {237-243},
        issn = {2349-6002},
        url = {https://ijirt.org/article?manuscript=208472},
        abstract = {India now runs a large part of its economic and social life through digital systems, and this has meant that huge amounts of personal data move between government bodies, businesses and online platforms every day. 
At the same time, technologies such as artificial intelligence, cloud computing, the Internet of Things, automated profiling and synthetic media are creating risks that older, narrower cyberlaw provisions were never designed to handle. India deals with these issues with the laws and rules like IT Act 2000, IT Rules 2021, DPDP Act 2023 and the DPDP Rules 2025. The main objective of my paper is to ask the question whether is this framework capable enough to keep up with the new technology or does it need new patches. The paper compares India’s system with the EU GDPR, the UK and Singapore’s PDPA in areas such as privacy rights, consent, data security, breach reporting, cross border data transfers, accountability and enforcement. It finds that India has created a strong legal base for the framework but its success will depend on proper implementation, capable regulators and clear guidance for new emerging technologies. 
This paper will recommend a new approach to regulations one that is reviewed on regular periods and is backed up by proper implemented guidance. The research will use the results of the gap analysis between these frameworks allowing to identify strength, limitations, weakness to be identified. 
A simple five-point comparative table is used to identify the differences between these frameworks. These steps can help India develop a stronger and more compatible framework which will support the growth of digital economy},
        keywords = {India’s Cyberlaw, Data Privacy, Data Protection, Cybersecurity, DPDP Act, Information Technology Act, GDPR, PDPA, Artificial Intelligence, Regulatory Gaps, Digital Governance.},
        month = {September},
        }

Cite This Article

Choudhary, A. J., & Taterh, D. S. (2026). India's Evolving Cyberlaw Framework: A Comparative Analysis of India’s DPDP Act, EU GDPR, UK Framework and Singapore’s PDPA. International Journal of Innovative Research in Technology (IJIRT), 237–243.

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