In the age of digitalised world, the information that's once out on the internet is omnipresent and is there permanently. Any and every information related to any person, thing or place is available by just a click on any device, anywhere, anytime. This has become a part of everyone's day to day life and has turned into a necessity.

But as everything has pros and cons of it, so is the case of this privilege of instant availability of information. And here the right to be forgotten could be seen as a remedy to this issue. In this paper the researcher would like to analyse the scope of the right to be forgotten vis a vis the Right to information and freedom of speech and expression provided under the Article 19[1] of the Indian Constitution.

Introduction:
The information on the internet is permanently available in this digital era that we all are living in. The use of internet to communicate and get information about every one and everything that is going around the world has become very easy by just a click on our devices. The social media and various new technologies help us to express and share our views with the world.

All this has turned into a major part of our lives and has become an essential necessity. But the researcher believes that every coin has two sides to it. Similarly the availability if all the information about everything and everyone on the internet has certain downfall attached to it.

The information provided by the search engines and various social media platforms also act as a provider of information that a person might want to keep private or might not want to reveal or share it with the world for example certain articles or news about the crimes committed by that person in the past, or certain images or videos of incidents and times which the individual finds to be embarrassing etc.

Different information that is out there on the internet about an individual irrespective of the fact whether it's true, right or wrong, false or is completely out of context, might result in causing harm to the individual or may act as a threat to the personal autonomy or dignity of the individual. Protecting the personal data which is out there on the internet is a complex task and there is a need for it to be very carefully due to it being a sensitive but also most important aspect of a person's life and privacy.

But today's digital era and our dependency on the internet and technology poses a serious threat to it. The researcher would like to state that the information on the internet is just like toothpaste, once both of them are out they cannot be put back. The world that we live in today is fully digitalised and every person is equipped with a mobile phone with internet access which makes it easy for everyone to access information, and this has led to a serious conflict between the right to information and right to individual's privacy. It also raises serious question with regards to the right of an individual to freely express and share his or her point of view versus the right to privacy.

All this causes concerns and that's where the concept of the right to be forgotten comes into picture. This right to be forgotten may act as an remedy to all the conflicts and issues mentioned above. Although this term is yet not recognised by neither the International Human Rights Instruments nor by most of the countries throughout the world. The scope of the right to be forgotten is also not defined properly.

The right to be forgotten although isn't a new concept as it came out in the year 2014, through decision given by The Court of Justice of European Union, but it has been widely demanded in the present times to make this right to forgotten a new human right. Talking about India, the researcher would like to state that there is no specific law in our country that grants the right to be forgotten although it has been recognised under the Personal Data Protection Bill,2019. [2]

Analysis:
The right to be forgotten is concept which is emerging in the legal world these days. It allows people to have a control over the information available in the public domain or on the internet about them by asking the search engines to remove certain information or data about them from the internet. This right has also been recognised by some countries, for example the European Court of Justice supported this right to be forgotten in 2014, it has also been recognised in Argentina by some judges and by various regulators of data-protection in many European countries also.

There are different opinions about the right to be forgotten by the scholars. The supporters of the concept believe and state that the legal principle behind the right to be forgotten is that the criminals who have served their sentence, should be free from any kind of association out there in public domain with their past crimes. And on the other hand the critics of the right to be forgotten state that this right is contradictory to the right to freedom of expression.

It has been heavily condemned in the South America by the scholars there, as according to them this right could be used by human rights offenders in order to hide and cover up their brutal acts. However the ones who support the right to be forgotten press upon the fact that in this digital age and information and data being available online leads to delay in forgiveness for a person and not just this but it also hampers the personal progress of the individual.

This debate about the right to be forgotten leads to a lot of unresolved and difficult questions with regards to the usage, access or control over the information on the internet vis-a-vis the right of the individuals to freely express and access information.

Right to freedom of expression and information [3]

The free exchange of ideas, opinions and information is protected under the right to freedom of expression[4] and right to information.[5] This is applicable on media throughout the world irrespective of the borders. This includes the right not just to share but also to receive the information. But right to freedom of expression is not an absolute right and is subject to certain restrictions.

The right to freedom of expression is recognised in nearly every national constitution and in most international human rights treaties including the Universal Declaration of Human Rights (UDHR),[6]the International Covenant on Civil and Political Rights (ICCPR),[7]the African Charter on Human and Peoples' Rights (African Charter),[8]the American Declaration of the Rights and Duties of Man (American Declaration),[9] and the American Convention on Human Rights (American Convention),[10] and  the European Convention on Human Rights (European Convention).[11]

The Right to privacy[12]

Right to privacy is a very broad concept which relates to the autonomy of the individual and also relates to the relationship amongst the person and the society which also includes the government, the companies and private persons. Again just like the right to freedom of expression and information the right to privacy is also not an absolute right.

The right to privacy is recognised in most international human rights treaties[13] and in nearly every national constitution.[14]It has been adjudicated upon by both international and regional bodies.[15]The right to privacy is also legally protected at the national level through provisions in civil and/or criminal codes.[16]Within the Americas, many nations have formalized privacy rights, either in constitutions or laws, under Habeas Data, which gives individuals the right, in the words of the Inter-American Commission on Human Rights, to modify, remove, or correct information due to its sensitive, erroneous, biased, or discriminatory nature.

Relation between Right to freedom of expression and information and The Right to privacy

Right to freedom of expression[17] and right to privacy[18] share a very complex relationship. The right to privacyof an individual needs to be protected in communications taking place online so that the individuals can freely enjoy their right of freedom of expression.[19]But on the other hand if any sort of private information is published it leads to the infringement of the of the individual's right to privacy.

The researcher also wants to state that as mentioned above both the rights are not absolute and are subject to certain restrictions under some circumstances. This means inter alia that States are not required to adopt measures that would protect the right to privacywhere that would constitute an undue restriction on freedom of expression.[20]In other words it can be stated that both the rights conflict occasionally but can be enforced mutually.These conflicts can be especially difficult to manage when the information at issue is both personal and public.[21]

The Right to be Forgotten

The right to be forgotten can be generally understood as the right of the individual over his or her personal information which is out in the public domain or on the internet, and the individual's right to get that information removed which is available in the public domain on several search engines and social media platforms or anywhere on the internet.

The supporter of the right to be forgotten strongly believe that the access to information needs to be restricted as with the passage of time a certain information may lose its importance. The right to be forgotten was conceived in the General Data Protection Regulation[22] and this right has also been upheld by European courts and by courts in UK. It has also been recently considered and encouraged by the Indian courts.

Now the researcher would like to discuss briefly about the right to be forgotten in different countries:

USA

US courts rather tend to the statement that restrictions to the right of free speech would invite timidity and self-censorship and very likely lead to the suppression of many items that would otherwise be published and that should be available to the public.[23]For decades, court practice defined the potential scope of a right to be forgotten in quite a narrow way since the justification for limiting the freedom of speech was tied to the constitutional scrutiny of highest order of public confidentiality interest, making it very difficult to satisfy this standard.[24]

Europe Union

Individuals are allowed to get their personal data removed from the internet under the GDPR[25] of the EU, but it's also been noted by the authorities that organisations aren't always supposed to do that. At the same time it has also been noted by EU that this 'right to be forgotten' is not absolute. And hence in certain cases related public interest, the removal of data can be refused for necessary purposes.

India

The first question that needs to be answered is whether thus right to be forgotten is recognised under our country's law, and to this the researcher would like to state that no, there is no legal provision under our Indian Law that provide for the right to be forgotten. The digital data is governed by the Information Technology Rules,2011[26] in our country and under that there is no specific provision that sheds any light on the right to be forgotten.

The Personal Data Protection Bill,2019[27] on the other hand covers the right to be forgotten under the protection of personal data of the individuals but this bill is still under the consideration of the government and is yet to be passed. The provisions of the PDP Bill have been discussed in the judgement by the Orissa High Court[28] for the first time. But the right to be forgotten recognised under the PDB Bill is not a right which is free from any kind of restrictions.

This right could only be enjoyed by the individual after an application is made to the 'adjudicating officer' and such application by the individual receives approval by the adjudicating officer. And it has been stated by the HC regarding the PDP bill that the right to be forgotten has been recognised by the said bill and this right could only be used for the prevention and restriction of disclosure of the personal data, only when certain conditions are there.

These are as follows:

1. The data or the information collected is no longer necessary for the purpose it was collected and the purpose for collecting the said data has been served.
2. It was made with the consent of the individual, whose consent was then withdrawn; or
3. The data or information that was collected or stated was against the law in force or the PDP Bill's provisions.

The emphasis was laid by the HC on the right to be forgotten in the given case as it was noted by the court that our country currently does not provide for any mechanism through which the data or information of any individual could be deleted or taken off the internet on his or her request. It was also noted by the HC that the online presence of the citizens causes serious issues for them due to the amount of harassment, threats and assaults that are faced by them online.

It was further stated by the HC that the institution of such a right would in turn help in improving the safety concerns for the women on the internet. Although in the present case it issue of deletion of content was not raised by the aggrieved woman and hence it was quite categorically stated by the HC, that since there is no specific provision to have the content removed from the internet, hence this right of the victim remains unaddressed.

The concept of the right to be forgotten' has earlier also been recognised by the Indian courts in certain cases, which are as follows:

1. The concept of right to be forgotten was dealt in our country by the High court of Gujarat[29], the first time.While the Court did not per se recognise the 'right to be forgotten'; the case arose as the Petitioner had led a case for the removal of a published judgment in which he had been acquitted.The Court did not grant an order for the removal of the judgment, as the petitioner had not been able to point out specific provisions of law that had been violated.The concept of the RTBF has also been discussed in more recent orders passed by various other high courts in India.[30]
    
2.  It was held by the Supreme Court in 2017 in the landmark case[31] that the right to be let alone forms an important part under the privacy and autonomy of a person. The importance of the right to be forgotten was also recognised by the SC in the given case and it was noted that if India would recognise the right to be forgotten as it's there under the GDPR[32], it would only mean that an individual who is no longer desirous of his personal data to be processed or stored, should be able to remove it from the system where the personal data/information is no longer necessary, relevant, or is incorrect and serves no legitimate interest.
   
   There were also certain limitations that were recognised by the SC over the right to be forgotten of an individual.
   
   The Sc noted that this right to be forgotten could not be claimed in situations where the information being questioned was essential for the following:
   • For the exercise of the right of freedom of expression and information.
   • Adherence of legal provisions.
   • Performance of any task or activity in furtherance of public interest or anything related to public health.
   • archiving purposes in the public interest.
   • For research purposes in the field of science, history or for fulfilling statistical purpose
   • Lastly, for the establishment, exercise and defence of the legal claims.
      
3. Certain references to the western countries trends regarding the recognition of the right to be forgotten by these countries in certain cases which are sensitive matters, was made by the Karnataka high Court in a decision.[33] It was requested by the petitioner to just remove the name of the his daughter from the cause title, because that could harm the reputation of the daughter as it could be easily found and searched on the internet.
   
   A declaration was requested by the daughter of the petitioner stating that there was no marriage between her and the defendant and it was also further argued by the daughter that how her name if would be out in the public domain through the order would cause issues as, it would have repercussions even affecting the relationship with her husband and her reputation that she has in the society. The decision of the court was in the favour of the petitioner and the name of the daughter was redacted from not just the cause title but also the order by the registrar of the court.

Recently this debate around right to be forgotten has been spurred again when a petition seeking his right to be forgotten has been filed in High court of Delhi on 22nd July 2021 by the reality tv actor Ashutosh Kaushik. He is seeking court order in order to get some of his past acts removed from the internet, which dates back to the years 2009 and 2013 respectively.

He is seeking removal of any kind of posts, pictures or videos or any information related to those incidents as according to him they cause him severe psychological trauma and pain. And it has been contended by him that the right to be forgotten forms an integral part of Article 21[34] of Indian Constitution i.e. the Right to life and it has been held by the SC that right to privacy also falls under the ambit of this right to life.

And hence, the petitioner states that the presence of that content online infringe his privacy and have a severe effect on his right to life and liberty. It has also been contended by the petitioner's lawyer that the presence of this content doesn't help anyone or serve any public purpose, rather just affects the petitioner's right to live with dignity. On the other hand it has been argued by the opposition party that the right to be forgotten still doesn't form the part of the law. The PDP Bill's section 20[35] covers the concept of the right to be forgotten but again, the PDB Bill is not yet a law.

From all the above discussion the researcher would like to mention certain arguments of both the sides i.e. for and against the right to be forgotten:

Arguments in support of the right to be forgotten:
This right to be forgotten is seen as a positive step in this digital age towards development of self-determination of an individual.

Some of the arguments in support of it are:

1. The right to control their information which is personal and anything related to their identity should reside with the individual in this digital age: Due to the surveillance that we are as an individual are put to, by the information communication technologies allowing not just the government but also any private person to interfere with other person's privacy by providing the access to all our activities online. So it becomes the responsibility of the law makers of any country to take care of the privacy and protect their personal data. Hence its always better to provide the individual the right of ownership of his or her own personal data and the right to be forgotten helps individuals to have control on their lives on a digital platform.
    
2. Balancing the public interest: Its argued by some people that the accessibility to all kinds of information should not be protected but only the ones which are related to public interest. And the personal information that is out there in public domain does not always serve any public interest but rather the accessibility to such information might lead to severe consequences on the individual's life.
    
3. No remedy against the information available on the internet and is accessed unlawfully: There are times when certain personal information or data is leaked online without their consent and which is unlawfully accessed by several people for example intimate pictures or videos of people, and we have no clarification or justification for this unlawful access to data online.
    
4. Reminded of past mistakes: Human is bound to make mistakes and it is not right that the person should be constantly reminded throughout his or her life of certain mistakes that were committed in past, even in cases when that information was our in public domain lawfully or was shared by the person itself with consent. If a certain person has undergone his punishment for the acts committed in past, it is unfair to put the person through same trauma throughout his life by failing to recognise the 'right to be forgotten', as that information is spreads all over the internet and is accessible through several search engines, which makes it nearly impossible for the individual to move on from the past and turn a new leaf.

Arguments against the right to be forgotten:
The concerns regarding the protection of data and privacy are well recognised by article 19[36] and it is never denied by the critics of the right to be forgotten that right to privacy needs to be protected in this digital era. However the critics of the right to be forgotten state that there are certain aspects that are not taken care by the given right which are as follows:

1. The right over accessibility to information about an individual should not reside with him or her: Just because a piece of information is regarding a person doesn't give the sole right to him or her over it or doesn't give them the ownership rights over it as it is considered to be an approach which is self-centred as the right of the public to share and get information is restricted by it.
    
2. Public interest in relation to freedom of expression:
   A person shouldn't need to justify himself or herself for publishing any information which is out in public domain and is not private. Also availability of information makes it easy for the researchers or the historians to ponder upon the cultural or historical insight. And hence it has been considered by the authorities of data collection that the collection of historical and cultural data � which may include personal data - should be encouraged and treated as a valid way to retain data beyond its 'operational utility' date.[37]
    
3. The opportunity to forgive should be given to people:
   The right to be forgotten doesn't provide a clear or true picture of the individual by allowing them to get rid of certain content from online. The ones who are seeking access to the information about the other individual should be granted the whole and true picture of the person and then they should be allowed to form their own opinions based on the whole story rather than just providing bits of it. Basically the individuals should be given the opportunity to forgive the mistakes committed by others rather than them to be 'forgotten'.
    
4. Restrictive of freedom of expression:
   The individual is allowed to completely allowed to remove the information or make it inaccessible under the right to be forgotten and hence this becomes restrictive of not just the right to freedom of expression but also right to information.

Need for Balance of interest
The researcher believes that there needs to be a balance of interest, while applying the restrictions on rights like right to freedom of speech and expression, right to information and right to privacy at the same time finding out suitability of the right to be forgotten. The right to be forgotten is not an absolute right.

The right to be forgotten is highly dependent on availability of personal data or information on the internet as this right cannot be claimed until and unless our certain information is known and out in the public domain. And this right to be forgotten definitely falls under the right to privacy as there needs to be some sort of origin of the information which could only happen through speech or our expression and then only that information can be protected or recorded as we want.

This could be explained by stating that we can preserve a life only after its born. Similarly if no information is out, nothing is expressed or spoken and no information is available on the internet no right to be forgotten can be enforced. Anything can only be protected only when it exists. So the researcher would like to state that the root of protection of information lies in right to speech and expression and not in the right to life or right to privacy.

The researcher believes that the balance of rights should be tested based on individual rights versus the collective interest. And in this digitalised world if a person is allowed to express his or her views under the right to freedom of speech and expression[38] then why can't be the other person also given the protection under the umbrella of right to be forgotten. As stated by Warren and Brandies, that 'forgetfulness' is the endless bliss of information which is spread or shared all over the internet. And also in the words of Warren and Brandies in a debate on right to privacy, the right to be forgotten can be the only solution for the speech and expression on the internet.[39]

Recommendations And Suggestions:
There are certain recommendations or suggestions that the researcher would like to make:

1. Certain minimum requirements should be met in order to strike a balance between the right to be forgotten and right to freedom of expression when this right to be forgotten is recognised by any legislation or courts or even any search engines for that matter.[40]
   
   The right to be forgotten should have certain basic features:
   
   • Individual right:
     This right should only be granted in order to protect the privacy or dignity of an individual
   • Protection of freedom of expression:
     The protection provided under right to be forgotten must balance it with the fundamental right of freedom of expression without infringing it.
2. As the matter related to the right to be forgotten is very complex, it is a complex techno-legal policy issue and hence there is a need of a multifaceted intervention and a very difficult balancing of interests.
    
3. Keeping our country's scenario in mind the researcher would like to state that the questions related to the rights of an individual shouldn't be decided based on case to case basis as its mentioned in the PDP Bill 2019 draft.
    
4. Until any specific or clear laws or provisions are passed in relation to the right to be forgotten, such cases must be dealt by the constitutional courts because they have the best knowledge to adjudicate such matters on a case to case basis.
    
5. Ideally, the 'right to be forgotten' should be enshrined in legislation whose guiding principles factor in the functional differences between apps and platforms.
    
6. It should be specifically and clearly mentioned in the proposed legislation that the invocation of right to be forgotten can't in turn lead to the obstruction in the working of free press.

Conclusion:
It can be concluded from the discussion above that recently the demand and debate around and about right to be forgotten has been doing rounds not just in our country but the world. There have been demands from various people to have the right to get the information deleted from the internet which damages their present and future and cause mental trauma.

But this right to be forgotten also tends to create a tiff and conflict between the right to freedom of speech and expression , right to information and right to privacy. And hence the researcher believes that the wide scope of the right to be forgotten needs to be evaluated keeping in mind the other mentioned rights too.

And a balanced approach needs to be adopted because right away deletion of anything cannot be asked for but a balanced approach with clearer and specific legal provisions need to be adopted by our country in order to resolve this issue. We lack in having a well-defined and properly stated policies and procedures with regards to the question of right to be forgotten which creates an issue and hence this needs to be taken care of.

There is also a huge lack of precedents or cases reacted to the same issue, which also hampers in the implication of the right to be forgotten as the regulatory framework of our country is pretty unclear and insufficient when it comes to the right to be forgotten. All these issues pose a huge threat in this new digital age and hence these issue need to be dealt correctly as our country doesn't have a settled position regarding the same, yet.

Although the Apex court has already stated that right to be forgotten cannot be given as an absolute right but at the same time different high Courts of our country have put forward different stands and views regarding the same. While the right to be forgotten has also been recognised under the PDP Bill, 2019[41] but there has been delays and it has still not been enacted and made into a law.

Lastly, the researcher would like to state that In the absence of any statutory framework to address this issue, the courts will continue to take stabs in the dark and fashion remedies as the situation demands.

Reference:
Acts:

• The Constitution of India, arts. 19,21.
• International Covenant on Civil and Political Rights (ICCPR), arts. 19,17.
• Universal Declaration of Human Rights (UDHR), arts. 12,19
• American Declaration on Human Rights, arts. 4,5,9,10
• African Charter, arts. 9,11.
• American Convention, arts. 13
• European Convention, arts. 8,10.
• The Information Technology Act 2000.

Articles:

• Alok Prasanna Kumar, Right to be Forgotten' in Indian Law :Law and Society Vol. 52, Issue No. 11, 18 Mar, 2017
• Philip M. Napoli. (2020) Connecting Journalism and Public Policy: New Concerns and Continuing Challenges. Digital Journalism 8:6, pages 691-703.
• Ashwinee Kumar, The right to be forgotten in digital age: A Comparative Study of the Indian Personal Data Protection Bill, 2018 & The GDPR, HPNLU SHIMLA, II SML. L. REV. 75 (2019).
• Inika Serah Charles, Aaron Kamath , Gowree Gokhale, High Court in India Reaffirms the Need for an Individual's 'Right to Be Forgotten' National Law Review, Volume X, 341 (2020)
• ARTICLE 19, The Right to be Forgotten: Remembering Freedom of Expression, 2016 available at:
  https://www.article19.org/data/files/The_right_to_be_forgotten_A5_EHH_HYPERLINKS.pdf (last visited on 12th September, 2021)
• Edward L. Carter, The Right to be Forgotten Oxford Research encyclopaedias 2016 available at https://doi.org/10.1093/acrefore/9780190228613.013.189 (last visited on 12th September, 2021)
• Rolf H. Weber, The Right to be Forgotten More than a Pandora's box? 2011 available at https://www.jipitec.eu/issues/jipitec-2-2-2011/3084/jipitec%202%20-%20a%20-%20weber.pdf (last visited on 12thSeptember,2021)
• Kunal Garg, The Right to be Forgotten in India: A Hustle over protecting personal data, Indian Law Journalavailable at https://indialawjournal.org/a-hustle-over-protecting-personal-data.php (last visited on 12th September,2021)
• Apoorva Mandhani, Do you have a 'right to be forgotten'? Here's what it means and how Indian courts view it The Print, 2021 available at https://theprint.in/judiciary/do-you-have-a-right-to-be-forgotten-heres-what-it-means-and-how-indian-courts-view-it/666226/ (last visited on 12th September,2021)
• Aayush Soni, Bigg Boss winner's plea shows 'right to be forgotten' cannot be viewed on a case-to-case basis The Print 2021 available at https://theprint.in/opinion/bigg-boss-winners-plea-shows-right-to-be-forgotten-cannot-be-viewed-on-a-case-to-case-basis/706021/ (last visited on 12th September,2021)
• Sanskruti Yagnik, Right to be Forgotten: A Case of Protecting human Dignity and Informational Self Determination, The Leaflet, 2021 available at https://www.theleaflet.in/right-to-be-forgotten-a-case-of-protecting-human-dignity-and-informational-self-determination/ (last visited on 12th September,2021)

Cases:

• Cox Broadcasting v. Cohn, 420 U.S. 469, 493-496 (1975)
• Subhranshu Rout @ Gugul v. State of Odisha [BLAPL No. 4592 of 2020]
• Dharmaraj Bhanushankar Dave v. State of Gujarat [Special Civil Application No. 1854 Of 2015].
• Vasunathan v. The Registrar General, High Court of Karnataka (2017 SCC OnLine Kar 424
• Zulfqar Ahman Khan vs. Quintillion Business Media Pvt. Ltd. and Ors (2019 (175) DRJ 660)]
• K.S. Puttaswamy v. Union of India [(2017) 10 SCC 1]
• [[Name Redacted] v. The Registrar, Karnataka High Court, Writ Petition No.62038 Of 2016].

End-Notes:

1. Constitution of India, art. 19
2. Personal Data Protection Bill,2019, S.20
3. Supra at 1
4. ibid
5. ibid
6. Article 19 UDHR
7. Article 19 ICCPR
8. Article 9 African Charter
9. Article 4 American Declaration
10. Article 13 American Convention
11. Article 10 European Convention
12. Constitution of India, art. 21
13. Article 12 of the UDHR; Article 17 of the ICCPR, Article 8 of the European Convention, Article 5,9 and 10 of the American Declaration on Human Rights, and Article 11 of the African Charter
14. US Department of State, 2010 Country Reports on Human Rights Practices, April 2011
15. HR Committee, Concluding Observations on Netherlands, CCPR/C/82/D/903/1999 [2004] UNHRC 60 (15 November 2004); Inter-American Court on Human Rights (Inter-American Court), Escher et al. v. Brazil, 9 July 2009; or the ECtHR's summary of European Court case-law on data protection.
16. US Department of State, 2010 Human Rights Report, op.cit.; Privacy and Human Rights, op.cit; Glasser (ed.), International Libel and Privacy Handbook, 2006
17. Supra at 1
18. Supra at 12
19. UN Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression (Special Rapporteur on FOE), A/ HRC/23/40, at paras 24-27
20. For example,a requirement for newspapers to notify the subjects of a news article before its publication; see European Court, Mosley v the UK, Appl. no. 48009/08, 10 May 2011
21. European Court, Satakunnan Markkinapörssi Oy and Satamedia Oy v. Finland, Appl. no. 931/13, 21 July 2015
22. General Data Protection Regulations (GDPR)
23. Cox Broadcasting v. Cohn, 420 U.S. 469, 493-496 (1975)
24. The privacy right under the Fourth Amendment is seen as a right against arbitrary use of data by governments.
25. Supra at 22
26. Information Technology Rules,2011
27. Supra at 2
28. Subhranshu Rout @ Gugul v. State of Odisha [BLAPL No. 4592 of 2020], High Court of Orissa, decided on 23 November 2020.
29. Dharmaraj Bhanushankar Dave v. State of Gujarat [Special Civil Application No. 1854 Of 2015]
30. Vasunathan v. The Registrar General, High Court of Karnataka (2017 SCC OnLine Kar 424); Zulfqar Ahman Khan vs. Quintillion Business Media Pvt. Ltd. and Ors (2019 (175) DRJ 660)].
31. K.S. Puttaswamy v. Union of India [(2017) 10 SCC 1]
32. Supra at 22
33. [[Name Redacted] v. The Registrar, Karnataka High Court, Writ Petition No.62038 Of 2016]
34. Supra at 12
35. Supra at 2
36. Supra at 1
37. Contribution of the Belgian Data Protection Authority to the European Commission's consultation on the comprehensive approach to personal data protection in the European Union,Brussels 2011
38. Supra at 1
39. Hiroshi Miyashita, The Right to Be Forgotten and Search Engine Liability 2(8) Brussels Privacy Hub (2016). Available at: https: //brusselsprivacyhub.eu/BPH-Working-Paper-VOL2-N8.pdf.
40. Google has started offering a right to be forgotten to victims of revenge porn worldwide, see Google, Revenge Porn and Search, 19 June 2015
41. Supra at 2

Also Read:

• Right to be forgotten in India