The concept of cyberstalking can be defined as a crime committed by someone who
stalks someone using the internet or another electronic device. The terms "cyberstalking"
and "online abuse" are interchangeable. It involves persistently intimidating or
threatening an individual. There are many ways to stalk someone, including
following them to their home or place of business, damaging their property,
leaving notes or objects behind, or making obnoxious phone calls. One of the
biggest advantages of this kind of crime is the anonymity that is provided to
cyber stalkers cyber stalking allows them to keep a check on the activities of
their victim without their identity being known to the world.
effective cyber tools are required to investigate cybercrimes, be ready to
protect against them, and bring victims to justice. Numerous psychological
factors, such as extreme narcissism, hatred, rage, retaliation, envy, obsession,
mental illness, power and control, thoughts of sadomasochism, sexual deviance,
internet addiction, or religious fervor, might be the cause of stalking.
Major factors are provided below:
- Fascination and attraction:
Obsession and attraction may be the driving forces
behind stalking. The victim might be sexually or mentally appealing to the
stalker. The line between admiring and stalking is thin.
The stalker tends to believe that the victim, who is typically a
stranger or famous person, is in love with him. It always involves someone's
- Retaliation and Hate:
Even though the victim is not the cause of the stalker's
feelings of anger and retaliation, he or she nonetheless becomes the focus of
the stalker. The stalker's apparent preferred medium for venting his feelings of
retaliation and hatred is the internet.
Stalking can have a strong jealousy component, especially when it
involves former partners and their present companions.
- Sexual Harassment:
It is said to be the main motive behind cyberstalking. This
is so because the internet reflects real life.
Based on the aforementioned reasons for stalking, a stalker may be obsessed,
furious, psychotic, or otherwise insane. There are three types of stalkers,
Delusional stalkers are those who feel the need to establish their dominance,
vengeful stalkers are those who want to exact revenge, and obsessional stalkers
are those who are motivated by their obsession with sexual harassment and
occasionally even love.
Victimization of Women
Women and small children are frequently the targets of such activities, which
can result in threats, harassment, violence, and trauma. Women are the group
most impacted by the growing loss of privacy in both the real world and the
virtual world. Cyberstalking is a significant example of a breach of women's
In addition, these abnormal behaviors have a significant
negative impact on every element of their lives due to the nature of the crime
and the target that was intended. Textual victimization and graphical
victimization are the two main types of cyber-victimization of women. To
humiliate the victim, graphic victimization may involve making, uploading, or
distributing obscene, insulting, and pornographic items online.
In many cases,
stalking turns into a man's quick response to a woman's rejection to enter into
any kind of relationship with him. The situation is much more concerning now
that internet trolls use social media platforms and instant messaging apps like WhatsApp to target female activists, journalists, celebrities, academicians, and
other professionals to toast the general public these women so they can
experience a sadistic pleasure.
On the internet, trolls, bullies, and stalkers specifically target women with
rude, libelous, and disparaging words and images. Women may experience
harassment and stalking even when they are not online due to pointless phone
calls and SMSs. Sometimes, this may lead to a complete ban on women utilizing
any such communication channel. This demonstrates a flagrant disregard for the
rights of women through improper online speech and expression.
violations of fundamental human rights, such as the right to equality outlined
in Article 14 of the Indian Constitution and the right to live in dignity
outlined in Article 21. Unfortunately, the Supreme Court ignored the way, being
persecuted in cyberspace as a result of the abuse of this right when it rendered
its decision in the landmark case of Shreya Singhal v. Union of India about the
legality of Section 66A of the IT Act, 2000. Because of how different electronic
media is from print media in terms of its nature, such victimization would be
perilous for women.
What Is Cyberspace?
Before delving deeper into the subject, a quick explanation of the basic terms
that will be used frequently, such as "cyberspace," is provided. The setting
where online communication occurs is referred to as "cyberspace." In other
words, it's a world that the internet has built.
A global domain inside the
information environment made up of an interconnected network of information
technology infrastructures, such as the Internet, telecommunications networks,
computer systems, and embedded processors and controllers, is referred to as
The virtual environment in which the electronic data of worldwide
PCs circulate" is another definition. This is a generalized description of the
internet. Cyberspace's primary trait is that it is made up of several computer
networks, switches, routers, servers, etc. It is a collection of different
infrastructures, including those for public health, banking, and the
transportation and financial sectors.
Physical Stalking V. Cyber Stalking
Understanding what physical stalking entails is necessary before discussing the
differences between physical and cyberstalking. Physical stalking entails
behaviors meant to torment the victim, including threats.
In some ways, cyberstalking is essentially a development of traditional
stalking, with the perpetrator using high-tech methods to carry out the crime (Petherick
2007). Cyberstalking is an increasing criminal concern in modern society, so it
is important to look more closely at the offender's actions and behaviors (Desai
& Jaishankar 2007). One of the first scholars to examine the frequency and
effects of cyberstalking was Bocij (2005).
Geographically speaking, the victim and the stalker are close. It is challenging
for a stalker to provoke another person to harass or threaten the victim. A
physical altercation is required. In contrast to physical stalking, there is a
possibility that the victim and the stalker may not reside in the same area. To
provoke a third party to harass or threaten the victim is a very simple
undertaking for a stalker.
It is not essential to engage in physical conflict to
fulfill the intended goal. Physical stalking activities are very predictable in
that the offender frequently follows the victim to their homes, places of
employment, or even to school. As a result, it is rather simple for
investigators to locate, catch, and then arrest the offender. Additionally, many
stalkers turn to leave unwanted written messages at the victim's home or place
of employment, and in some cases, they will make threatening phone calls to the
victim to instill fear and intimidation.
All of these tactics can frequently be
used to identify the offender with relative ease (Reno 1999). As previously
indicated, the aforementioned offenses often leave behind a physical trail of
evidence that will surely be used to build a criminal case against the
The very high likelihood that both offender types had a past
intimate relationship, whether actual or perceived, with the victim, is another
interesting contrast between the stalker and the cyberstalkers; yet, the
cyberstalkers is more likely to pick their victims at random (Bocij & McFarlane
2003; Reno 1999). Nearly 50% of all cyberstalking occurrences, according to Reno
(1999), involved strangers who were first approached in a seemingly innocent way
online. Cyberstalkers can easily obtain a great amount of personal information
thanks to the Internet (Reno 1999).
Numerous brokerage websites that target
people merely looking for friends or family might provide easy access to
information that was once regarded as private and sensitive a few decades ago
(Reno 1999). Some of these websites are free, but the majority will request a
user's name, phone number, address, social security number, date of birth, and
other private identifying information in exchange for a nominal service fee
The majority of these brokerage websites were created to assist
people in reconnecting with old friends and loved ones, but like anything else,
they are vulnerable to misuse by those who wish to take advantage of them.
The aforementioned distinctions have led some criminologists to advise against
finding a way to stop cyberstalking. Regulations can be used to prove guilt and
ultimately punish physical stalking, but a new mechanism must be developed to
guard against cyberstalkers. The Actus Reus and Mens Rea components of crime
should be covered by this new system. This new system must deal with addressing
the challenges of crime identification, evidence gathering, and jurisdictional
Remedies Provide Under Law
In this section, the author will concentrate on the legal provisions that are
specifically specified in the Indian Penal Code, of 1860 and the Information
Technology Act, of 2000. There must be an explanation of how these statutes
apply to cyberstalking and under which laws the criminal may be arrested.
Lawmakers in India created laws that are gender discriminatory because they saw
women as the weaker group in society and wanted to protect them.
There are no specific laws that address the problem of online stalking. However,
the author has attempted to clarify a few sections of the Indian Penal Code and
the Information Technology Act that are somehow related to this crime, and an
explanation of the relationship between the laws and the offense has been
Let's throw some light on what Indian law states concerning cyberstalking in
- Section 354D of IPC defines "stalking". It reads as follows:
Any man who:
- follows a woman and contacts, or attempts to contact such woman to foster
personal interaction repeatedly despite a clear indication of disinterest by
such woman; monitors the use by a woman of the internet, email, or any other
form of electronic communication commits the offense of stalking;.."
Following the Delhi gang rape case, the clause was added by the Criminal
Amendment Act of 2013. This section examines both traditional stalking and
online stalking. The provision specifies its purview in terms of behaviors that
constitute "stalking" as a crime. The section makes it quite clear that anyone
trying to keep tabs on a woman's online activities is engaging in stalking. As a
result, the stalker will be charged with an offense under Section 354D of the
Indian Penal Code if he engages in any of the behaviors listed in the section.
This section has many flaws, including the fact that it exclusively acknowledges
"women" as victims while ignoring the possibility of victims among men.
According to the Section, anyone who attempts to watch how a woman uses the
internet, email, or any other form of electronic communication is guilty of the
crime of cyberstalking. We can tell that it only gives attention to ladies. It
is therefore discriminatory against women. Second, the "means of monitoring" has
not been brought up by lawmakers. It is possible for someone to act stalking
even if they have no intention of doing so.
- Obscenity is defined in Section 292 of the IPC. The act of sending vulgar or
offensive content to a victim by email, text message, social networking site, or
other means falls under the definition of cyberstalking. When a stalker sends
obscene material online with the goal that the recipient would read, see, or
hear the content of the message, he or she is in violation of Section 292 of the
Indian Penal Code and is guilty of stalking.
- Crimes of "criminal intimidation by anonymous communication" are covered
in Section 507 of the IPC. According to this clause, it constitutes an offense when
a stalker makes an effort to conceal his identity so that the victim is
uninformed of the source of the threat. Thus, it ensures anonymity, which is a
key component of cyberstalking. If the stalker makes an effort to hide their
identity, they are in violation of this provision.
- Section 509 of IPC relates to the modesty of women reads as follows: "Word,
gesture or act intended to insult the modesty of a woman.�Whoever, intending to
insult the modesty of any woman, utters any word, makes any sound or gesture, or
exhibits any object, intending that such word or sound shall be heard, or that
such gesture or object shall be seen, by such woman, or intrudes upon the
privacy of such woman, shall be punished..."
If a stalker's actions interfere with a woman's right to privacy by gestures, or
words transmitted through e-mails, messages, or posts on social media, they may
be charged under this clause. He will be charged with an offense under Section
509 of the Indian Penal Code if he engages in any such actions.
numerous problems with Section 509. Some of these include the fact that it is a
gender-biased provision because it solely considers a woman's modesty and
ignores the fact that cyberstalking is a crime that can affect both men and
women and is therefore not only a crime against women.
It is a requirement of
this section that the gesture, sound, or words be said, heard, or seen,
accordingly. Since words cannot be uttered, gestures cannot be seen, and sounds
cannot be heard online, cyberstalkers can easily avoid punishment under this
clause. Last but not least, conversations on the internet cannot be used to
infer a person's intent to offend a woman's modesty.
- The Indian Penal Code's Section 292 is mirrored in Section 67 of the
Information Technology Act, 2000. This section deals with the dissemination
of pornographic material in "electronic form." hence, this part on online
stalking is covered. The stalker will be charged with an offense under
Section 67 of the IT Act if he attempts to broadcast any lewd information
about the victim in electronic forms, such as on social media, in an effort
to intimidate the victim.
- The Information Technology Act of 2000's Section 67A addresses one
aspect of the crime of cyberstalking. As a result of the 2008 modification, this provision
was added. It stipulates that a stalker will be found guilty of an offense under
Section 67A of the IT Act and will be penalized appropriately if he seeks to
disseminate any "sexually explicit" material in electronic forms, such as
through emails, messages, or on social media. The Information Technology Act of
2000's Section 67A addresses one aspect of the crime of cyberstalking. As a
result of the 2008 modification, this provision was added. It stipulates that a
stalker will be charged with an offense under Section 67A of the IT Act if he
seeks to disseminate any "sexually explicit" material in electronic forms, such
as through emails, messaging, or social media.
- Section 66E of the Information Technology Act, 2000, and Section 354C of
the Indian Penal Code deal with "voyeurism." Section 66E reads as follows:
"Whoever, intentionally or knowingly captures, publishes or transmits the image
of a private area of any person without his or her consent, under circumstances
violating the privacy of that person, shall be punished."
Section 354C reads as follows:
"Any man who watches, or captures the image of a woman engaging in a private act
in circumstances where she would usually have the expectation of not being
observed either by the perpetrator or by any other person at the behest of the
perpetrator or disseminates such image shall be punished�"
In order to do harm, the stalker might gain access to the victim's account by
hacking and posting personal images of the victim on social networking sites. In
the victim's mind, there is despair and a feeling of threat. Both of the
aforementioned sections are intended to make it illegal to publish or take
images of someone else's private acts without that person's permission. In
contrast to Section 345C, which is somewhat biased towards women, Section 66E is
more general because it refers to the victim as "any individual." In accordance
with � 354C, the victim must be a "woman."
The act of voyeurism is covered by the Indian Penal Code Section 354C. Because
the victim must be a "lady" to be attracted to this part, its scope is quite
limited. However, unlike Section 354C of the Indian Penal Code, Section 66E of
the Information Technology Act has a broader definition of voyeurism. The victim
is referred to as "any individual" in Section 66E. Therefore, the victim does
not have to be a "woman" to obtain justice under this clause. The Information
Technology Act of 2000's Section 66E may be used by the victim if he is a man.
The Indian Penal Code, 1860 and the Information Technology Act, 2000 do not
specifically address the problem of cyber stalking and the threatening or
defamatory messages made by the stalker while stalking the victim via texts,
phone calls, e-mails, or by publishing blogs under the victim's identity.
Although some of the provisions of the aforementioned Acts, which are listed in
the aforementioned chapters, may be used to penalize the perpetrator, no express
provision specifically addresses this offense. Although it is quite simple to
commit this crime, its consequences are very severe. Both the victim's physical
and emotional health may be negatively impacted. The existing provisions'
penalty must be enhanced while keeping the victim's welfare in mind. 
Landmarks Cases On Cyber-Stalking In India
Case of Manish Kathuria 
The Delhi Police reported the first case of cyber stalking in India in 2003, and
the Manish Kataria case:
which entailed the stalking of Ritu Kohli-was the
impetus behind a 2008 revision to the IT Act. In her complaint, Ms. Kohli
claimed that someone had been exploiting her identity to engage in a vulgar
online talk at a certain website. The woman allegedly received calls from
various locations as a result of the man allegedly giving her phone number to
other chat room users.
Her personal life was negatively impacted by this,
suffering great hardship, trauma, and harassment. Finally, as part of their
investigation, authorities were able to track down Manish Kathuria after using
the IP addresses he had used to commit the crime. Kathuria admitted to the crime
and was detained. Under Section 509 of the Penal Code, 1860 (IPC), a charge was
filed for "outraging the modesty" of his victim.
Since the IT Act had not yet
become effective when the complaint was submitted, it was not used in this case.
Due to this instance, Indian lawmakers were aware of the necessity for
particular legislation to deal with online stalking. However, Section 66A wasn't
introduced until 2008. Therefore, cases were reported in accordance with this
provision until the Supreme Court of India declared it to be unconstitutional.
It is important to note that a Section 509 analysis does not specifically
identify cyberstalking. In these situations, it is still difficult to prove
incidents of cyberstalking in accordance with the law.
- Karan Girotra V. State 
Shivani Saxena filed a police report alleging that while she had wed Ishan,
their union fell apart after only a few days because Ishan was unable to carry
it through. Following the completion of one year of their marriage, it was
peacefully agreed that both of them would file a joint petition, on the basis of
mutual consent, for the award of divorce. Thereafter, both parties would be free
to remarry. While this was going on, Shivani met Karan Girotra through an online
chat and accepted his marriage proposal. Shivani declined the same because she
was still married.
Karan once took her to a place, made her drunk by offering
her beverages, and then sexually assaulted her on the pretense of getting her to
his family members. In addition, Karan took lewd pictures of her and began
requesting sexual favors from her under the threat of revealing the pictures.
Many goods, including a Santro Car, were handed to Karan by the complainant's
family as part of the Roka ritual. Finally, he told the complainant's mother
that the engagement had been broken off. As a result of Shivani's complaint, a
case was opened under Sections 328 and 376 of the IPC as well as Section 66-A of
the IT Act.
- Case of Yogesh Prabhu (First case of cyberstalking in Mumbai) 
Despite the low conviction rate for cyberstalking after the IT Act's amendments
took effect in 2008, the Mumbai cyber unit achieved the first-ever conviction
under the IT Act in Maharashtra in July 2015. In 2009, the cell looked into the
matter because of online stalking. Yogesh Prabhu was found guilty by a
metropolitan magistrate court of stalking and emailing his coworker offensive
photos. Under sections 66-E of the Information Technology Act of 2008
(punishment for violation of privacy) and 509 of the Indian Penal Code (word,
gesture, or act intended to insult the modesty of a woman), the court sentenced
him to three years in prison and fines of Rs. 10,000 and Rs. 5,000,
Addressing Cyber Stalking In India: Trials
There is no question that combating cybercrimes requires solid information and
technological understanding from the time that evidence is gathered until it is
acknowledged by the legal system. Unfortunately, the nation does not
currently have the best practices for investigating cybercrime.
some of the challenges involving cyberstalking:
- Global Crime & Lack of jurisdiction:
The jurisdiction to conduct an
investigation is a significant problem because cyberstalking is a transnational
offense. Every time a cybercrime is done, the server of the computer or other
electronic device that was used to commit the crime may be outside the Indian
- Anonymity of Wrong-doer:
One of the main characteristics of the internet is
its capacity to maintain user anonymity, which is thought to be useful for the
perpetrators since it allows them to maintain their identity while appearing to
- Poor state of Investigation capabilities:
India also has weak capacities for cybercrime investigation. The necessary infrastructure does not exist to address
technological crime. As a result, the prosecution cannot gather sufficient
evidence to support its case.
- Tampering of evidence:
Electronic evidence is simple to alter due to
cyberspace's high degree of connectivity. At the time of evidence collection and
preservation, law enforcement authorities are not well-equipped to prevent such
- Enhanced Vulnerabilities on Electronic Media:
Due to the fact that the internet has no physical limits, it has a larger
audience and people sitting in various areas can watch the harassment,
abuse, etc. Additionally, with the help of cutting-edge technology, the
internet has the capacity to morph images, distorted voices, and other
things that could lead to major social disorders. The Internet offers more
opportunities to infringe Article 21's fundamental rights to life, liberty,
Conclusion And Recommendations
It is very well mentioned that if you want to change the existing condition, you
must get rid of the outdated model of handling the circumstance and create a
new, effective model. The phrase "cyber stalking" is relatively new. Recently,
it has drawn the attention of the judiciary and legislators.
As it becomes
exceedingly difficult for enforcement agencies to handle such cases, there have
been many instances where the necessity for strong legislation was felt. Cyberstalking is now recognized as a serious offense. The victim's emotional and
physical health is significantly impacted. The author has made an effort to
discuss the term "cyberstalking" in length, as well as its nature and extent, in
On the internet, cyberstalking is a serious kind of harassment. Additionally,
the courts face a dilemma in determining the proper jurisdiction to deal with
such an offense. Therefore, the IT Act needs to be reviewed in order to allow
for the prosecution of cyberstalking cases, and the law enforcement apparatus
needs to be better equipped to deal with such issues. In order to lessen the
vulnerability of online users, the issues involving law and technology in
dealing with such offenses must be appropriately addressed.
Some claim that it is a new type of stalking or an expanded form of
cyberstalking, but it seems to be more than that. Its very nature is a new kind
of criminality. We've seen that the stalker's goal is to bother and threaten the
victim. Therefore, criminal conduct is involved. On this matter, several nations
have laws. The instances cannot be handled effectively under any of the current
provisions. There is no specific legislation on the subject in India.
Few recommendations are made for the betterment of the redressal system for
- Strict laws at the national level; it is imperative to make the necessary
changes to the current laws or to reinstate Section 66A of the IT Act with
the necessary regulations in the absence of a specific provision to address
instances of cyberstalking.
- Interstate cooperation is required; the investigating agency is unable
to finish its investigation because of the other state's grave lack of
cooperation and coordination. A Cyber-Crime Inter-State Cooperation Cell may
be established in this regard and attached to each cyber cell to provide
exclusive information about such crimes.
- Action at the personal level; it is necessary to take preventative
measures, such as adequate security measures to ensure that personal
information is not disclosed on the internet in inappropriate form, in order
to protect oneself from such cyberspace exploitation. It shouldn't be too
simple for criminals to guess passwords. Social media privacy settings make
it easy to block annoying accounts. The same action must be taken to prevent
- Role of Internet Service Providers; The Internet Service Provider has
taken a few measures to limit the stalker's harassing behaviour. Few
services offer the option to report abuses. For instance, Facebook, which
was already mentioned, has some privacy rules that allow us to prevent
strangers from sending messages with offensive language and abusive
behaviour. 25 Internet service providers exercise control by placing
erroneous emails in the spam folder.
When it comes to locating the stalker, there is a requirement for cooperation
between Internet service providers and law enforcement authorities.
If the crime of cyberstalking rises quickly, only time will tell how effective
these measures are. However, in light of taking precautions, the requirement for
legislative provisions cannot be disregarded. Effective legislative measures are
necessary to combat such cybercrimes.
- The Indian Penal Code, 1860 Act No. 45 OF 1860 1* [6th October, 1860.]
- The Information Technology Act, 2000 [Act No. 21 of 2000]
- Abhiraj Thakur, Cyberstalking: A Crime or A Tort, Jun. 21, 2016.
- Radosevich, Thwarting The Stalker: Are Anti-Stalking Measures Keeping Pace With Today's Stalker? 2000 U. Ill. L. Rev. 1371 2000.
- B. Spitzberg and G. Hoobler, Cyberstalking and the Technologies of Interpersonal Terrorism, 4(1) New Media & Society 71 (2002).
- BH Spitzberg and WR Cupach, the State of the Art of Stalking: Taking Stock of the Emerging Literature, 12 Aggression And Violent Behaviour 64 (2007).
- Michael L. Pittaro, Cyberstalking: An Analysis of Online Harassment And Intimidation, International Journal of Cyber Criminology, 2007.
- Cyber Stalking and The Plight of Women in India � A Legal Perspective, 9 RMLNLUJ (2017) 175.
- D. Halder and K. Jaishankar, Cyber Crimes against Women in India: Problems, Perspectives and Solutions, 3(1) TMC ACAD. J. 48, 55 (2008).
- D. Lamplugh& P. Infield, Harmonising Anti-Stalking Laws, 34 Geo. Wash. Int'l L. Rev. 853 2002-2003.
- David C. Potter, The Jake Baker Case: True Threats and New Technology, 79 B.U. L. Rev. 779 1999.
- Divij Joshi, India's Criminal Law Amendment to include Cyberstalking, Harassment an,d Voyeurism, CIS, (2013).
- Divij Joshi, The Criminal Law Amendment Bill 2013 � Penalising 'Peeping Toms' and Other Privacy Issues, CIS, (2016).
- Dr. DebartiHalder, Creating Awareness of Online Victimization using Social Media: A Therapeutic Jurisprudential Approach, June 9, 2015.
- Dr. DebratiHalder, Cyber Stalking Victimisation of Women: Evaluating the Effectiveness of Current Laws in India from Restorative Justice and Therapeutic Jurisprudential Perspectives, SSRN 103, 103-130 (2015).
- Leroy McFarlane & Paul Bocij, Cyberstalking: The Technology of Hate, 76 Police Journal 204 (2003).
- DR. S.K. MOHAPATRA, Victimisation of Women Under Cyberspace in Indian Environment, in 2 (3(1)) International Journal Of Academic Research, 221 July-September, 2015
- KW Seto, How Should Legislation Deal With Children as the Victims and Perpetrators of Cyberstalking?, 9 CARDOZO WOMEN‟S L. J. 67, 73-74 (2002).
- Indian Penal Code, 1860, No.45, Acts of Parliament, 1860.
- Indian Penal Code, 1860, No.45, Acts of Parliament, 1860.
- Information Technology Act, 2000, No. 21, Act of Parliament, 2000.
- Indian Penal Code, 1860, No.45, Acts of Parliament, 1860.
- Vijay Mukhi and Karan Gokani, Observations on the Proposed Amendments to the IT Act 2000.
- Sandhya Soman, Cyberstalking Makes First Entry Into Legal Debate, available at http://epaper.timesofindia.com/Repository/ml.asp?Ref=VE9JQ0gvMjAxMy8wMy8xOCNBcjAwNDAy (last visited Dec 22, 2022).
- Sandhya Soman, Cyberstalking Makes First Entry Into Legal Debate, available at http://epaper.timesofindia.com/Repository/ml.asp? (last visited Dec 22, 2022).
- See Cyber cell's first conviction: Man gets 3 years for sending obscene messages, stalking colleague, Indian Express, Jul. 4, 2015 available at http://indianexpress.com/article/cities/mumbai/cyber-cells-first-conviction-man-gets-3-years-for-sending-obscene-messages-stalking-colleague/ (last visited Dec 23, 2022).
- See Franklin Witter, Legal Aspects Of Collecting And Preserving Computer Forensic Evidence, available at http://www.giac.org/paper/gsec/636/legal-aspects-collecting-preserving-computer-forensic-evidence/101482 (last visited Dec 23, 2022).
- See generally BILL NELSON, AMELIA PHILLIPS & CHRISTOPHER STEUART, Guide to
Computer Forensics and Investigation 153 (2010)
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