1. Introduction

Digital Biosurveillance Governance refers to the legal, constitutional, ethical and institutional framework governing the collection, processing, monitoring, storage, sharing and use of biological and health-related information through digital technologies.

It involves the use of modern technologies to monitor biological conditions, disease outbreaks, human health patterns and population-level biological risks.

Digital biosurveillance combines several technologies, including:

Artificial intelligence-based disease detection.

Digital health surveillance platforms.

Biometric identification systems.

Genomic and DNA databases.

Electronic health records.

Wearable health-monitoring devices.

Wastewater-based disease surveillance.

Digital vaccination certificates.

Contact-tracing applications.

Predictive epidemiological algorithms.

For example, during an infectious disease outbreak, government authorities may collect information about individuals' symptoms, vaccination status, geographical movements and medical histories to identify potential transmission patterns.

Although these technologies can improve public health protection, they also create significant legal concerns involving privacy, bodily autonomy, discrimination, data security, governmental surveillance and misuse of sensitive biological information.

Digital biosurveillance governance therefore seeks to balance two competing interests:

Public interest: Preventing disease transmission and protecting population health.

Individual rights: Protecting privacy, dignity, autonomy and confidentiality of personal biological information.

An important academic distinction is that digital biosurveillance governance is a developing legal framework rather than a separately recognised, comprehensive legal doctrine in Indian law.

2. Meaning and Scope of Digital Biosurveillance Governance

Digital biosurveillance governance can be understood through three interconnected dimensions.

A. Biological surveillance

Biological surveillance involves monitoring biological information to identify health conditions, infectious diseases, genetic characteristics and potential public-health threats.

Examples include:

Monitoring genetic mutations.

Identifying infectious disease outbreaks.

Tracking antimicrobial resistance.

Monitoring biological samples.

Analysing population health patterns.

B. Digital surveillance

Digital surveillance involves the technological collection and processing of biological information through electronic systems.

Examples include:

Mobile health applications.

Digital identity systems.

AI-powered medical monitoring.

Electronic patient databases.

Location-based disease monitoring.

C. Governance and accountability

Governance establishes the legal limits within which public authorities, hospitals, research institutions and private technology companies may collect and use biological information.

It includes:

Lawful collection of biological data.

Consent and legitimate processing.

Purpose limitation.

Data minimisation.

Independent oversight.

Cybersecurity.

Accountability for misuse.

Deletion and retention restrictions.

Judicial remedies.

The central legal question is whether public-health surveillance is necessary, lawful and proportionate to the biological risk being addressed.

3. Constitutional Framework in India

Digital biosurveillance directly affects several fundamental rights protected by the Constitution of India.

A. Article 21 – Right to Life, Privacy and Personal Liberty

Article 21 protects life and personal liberty. The Supreme Court has interpreted this provision to include privacy, dignity and individual autonomy.

In digital biosurveillance, Article 21 protects individuals against arbitrary collection, excessive retention and unauthorised disclosure of biological and medical information.

For example, government authorities cannot automatically assume that the public-health objective justifies unrestricted access to every individual's genetic information.

B. Article 14 – Right to Equality

Article 14 prohibits arbitrary State action and guarantees equality before the law.

Digital biosurveillance systems may create discrimination through:

Genetic profiling.

Automated health-risk classifications.

Predictive disease assessments.

Disability-based exclusion.

Discriminatory insurance or employment decisions.

If an algorithm classifies certain communities as high-risk without reliable scientific justification, the classification may raise constitutional concerns under Article 14.

C. Article 19 – Fundamental Freedoms

Digital surveillance can indirectly restrict freedom of speech, movement, association and expression.

Continuous monitoring may discourage individuals from attending public gatherings, consulting particular medical professionals or participating in legitimate research activities.

Therefore, surveillance must not unnecessarily interfere with constitutionally protected freedoms.

D. Article 20(3) – Protection Against Self-Incrimination

Compulsory biological or psychological examinations may raise questions concerning the protection against compelled self-incrimination.

The distinction between physical biological evidence and testimonial compulsion is particularly important.

The constitutional validity of compulsory testing must be evaluated according to the nature of the test and applicable legal safeguards.

4. Important Principles of Digital Biosurveillance Governance

4.1 Legality

Every governmental biosurveillance programme must have an appropriate legal foundation.

An executive authority should not establish unrestricted biological surveillance merely through administrative instructions.

The enabling legislation should identify:

The competent authority.

The purpose of surveillance.

Categories of information collected.

Conditions for collection.

Duration of surveillance.

Oversight mechanisms.

Available legal remedies.

4.2 Necessity and Proportionality

Surveillance must be necessary for achieving a legitimate public objective.

For example, collecting limited information about an infectious disease outbreak may be justified. However, collecting unrelated genetic, financial and location information from the entire population may be excessive.

The proportionality analysis requires consideration of:

Legitimate objective.

Suitability of the surveillance measure.

Necessity of the measure.

Availability of less intrusive alternatives.

Balance between public benefit and individual rights.

4.3 Informed Consent

Biological information is particularly sensitive because it may reveal information about an individual's identity, ancestry, inherited conditions and family relationships.

Consent-based systems should clearly explain:

What information is collected.

Why it is collected.

Who can access it.

Whether it will be shared.

How long it will be retained.

Whether it will be used for secondary research.

However, consent is not the only possible legal basis for public-health surveillance. Specific statutory powers may permit certain processing without individual consent, subject to constitutional and statutory restrictions.

4.4 Purpose Limitation

Information collected to monitor an infectious disease should not automatically be used for unrelated purposes.

For example, a government authority collecting vaccination information should not automatically repurpose that information for employment discrimination or unrelated law-enforcement profiling.

4.5 Data Minimisation

Authorities should collect only the biological and personal information reasonably necessary for the identified purpose.

Where aggregate or anonymised information can achieve the public-health objective, collecting identifiable individual-level information may be unnecessary.

4.6 Data Security and Confidentiality

Biosurveillance databases may contain extremely sensitive information.

Appropriate security measures include:

Encryption.

Access controls.

Authentication.

Security audits.

Restricted data sharing.

Breach notification procedures.

Secure deletion.

Accountability for unauthorised access.

4.7 Independent Oversight

A legitimate biosurveillance system requires effective institutional supervision.

Oversight should examine whether surveillance is lawful, necessary, scientifically justified and proportionate.

An independent review mechanism is especially important where the government itself collects and analyses biological information.

5. Major Indian Case Laws

The following judgments provide the principal legal foundations for developing digital biosurveillance governance in India.

Case 1: K.S. Puttaswamy v. Union of India (2017)

Supreme Court of India · (2017) 10 SCC 1

Foundational constitutional precedent

Facts:

The case concerned whether the Indian Constitution protects an independent fundamental right to privacy.

The Union Government questioned whether privacy was constitutionally protected, relying on earlier decisions concerning personal liberty.

Legal issue:

Whether privacy is a fundamental right under the Indian Constitution.

Judgment:

A unanimous nine-judge Constitution Bench recognised privacy as a fundamental right protected by the Constitution, particularly through Article 21 and the freedoms guaranteed under Part III.

The judgment recognised informational privacy as an important dimension of the right to privacy.

It also established a three-part test for restrictions on privacy:

Legality.

Legitimate State aim and necessity.

Proportionality.

Relevance to digital biosurveillance:

This judgment is the constitutional foundation for challenging arbitrary biological surveillance.

For example, if a government authority creates a centralised genetic database without adequate legal safeguards, individuals may challenge the measure on privacy grounds.

The judgment also recognises that privacy concerns can arise from both governmental and non-governmental entities.

Case 2: K.S. Puttaswamy v. Union of India (Aadhaar Case, 2018)

Supreme Court of India · (2019) 1 SCC 1

Facts:

The constitutional validity of the Aadhaar identification system was challenged, particularly concerning the collection and use of biometric and demographic information.

Legal issue:

Whether compulsory or extensive biometric identification and associated data-linking arrangements violated constitutional privacy protections.

Judgment:

The Supreme Court upheld the Aadhaar framework subject to important limitations and invalidated certain aspects of the scheme.

The judgment emphasised that biometric identification and data collection must operate within constitutional limits.

Relevance to digital biosurveillance:

The case is significant for:

Biometric surveillance.

Centralised biological databases.

Identity verification.

Data security.

Government access to personal information.

Restrictions on private-sector use of Aadhaar authentication.

It demonstrates that administrative efficiency and welfare delivery do not automatically justify unrestricted collection or use of personal information.

Case 3: People's Union for Civil Liberties v. Union of India (1997)

Supreme Court of India · (1997) 1 SCC 301

Facts:

The case concerned telephone interception and the constitutional implications of government monitoring of private communications.

Legal issue:

Whether telephone tapping could violate privacy and personal liberty.

Judgment:

The Supreme Court recognised that telephone conversations are protected by the right to privacy and prescribed procedural safeguards for interception under the Telegraph Act.

The Court emphasised safeguards relating to authorisation, review and duration.

Relevance to digital biosurveillance:

Although this case concerned communication interception rather than biological data, its safeguards are relevant to modern digital surveillance systems.

It supports the principle that surveillance must be legally authorised and subject to procedural control.

Case 4: Kharak Singh v. State of Uttar Pradesh (1963)

Supreme Court of India · AIR 1963 SC 1295

Facts:

The petitioner challenged police surveillance conducted under the Uttar Pradesh Police Regulations.

The surveillance included monitoring his movements and domiciliary visits.

Legal issue:

Whether police surveillance violated personal liberty under Article 21.

Judgment:

The majority invalidated domiciliary night visits as unconstitutional, although it did not recognise a general fundamental right to privacy in the manner later established in Puttaswamy.

Relevance:

The judgment demonstrates that physical surveillance and continuous monitoring can interfere with personal liberty.

Its reasoning provides historical foundations for examining digital monitoring of individuals.

Case 5: Gobind v. State of Madhya Pradesh (1975)

Supreme Court of India · (1975) 2 SCC 148

Facts:

The petitioner challenged police surveillance regulations that permitted monitoring of persons considered potential offenders.

Judgment:

The Supreme Court acknowledged privacy interests and accepted that surveillance may be permissible in limited circumstances, provided it is supported by compelling public interests and appropriate legal restrictions.

Relevance:

The decision is important for understanding the relationship between crime prevention and individual privacy.

In digital biosurveillance, it supports the proposition that the State may monitor legitimate risks but cannot exercise unlimited surveillance powers.

Case 6: Selvi v. State of Karnataka (2010)

Supreme Court of India · (2010) 7 SCC 263

Facts:

The case concerned the compulsory administration of narcoanalysis, polygraph examinations and brain electrical activation profile tests to accused persons.

Legal issue:

Whether involuntary administration of these techniques violated constitutional protections.

Judgment:

The Supreme Court held that involuntary administration of the tests violated Article 20(3) and Article 21.

The Court emphasised bodily integrity, mental privacy and personal autonomy.

Relevance:

This judgment is particularly significant for biological and neurological surveillance.

It establishes important limits on the compulsory extraction of information through techniques that interfere with bodily and mental autonomy.

Case 7: Jacob Puliyel v. Union of India (2022)

Supreme Court of India · (2022) 7 SCC 157

Facts:

The petitioner challenged aspects of the government's COVID-19 vaccination policy, including concerns relating to vaccine approval, clinical evidence and disclosure of adverse-event information.

Legal issue:

Whether vaccination-related government policies could override individual autonomy and privacy.

Judgment:

The Supreme Court recognised bodily integrity and personal autonomy under Article 21.

It held that an individual's consent to medical treatment is an important constitutional consideration and that restrictions affecting unvaccinated individuals require justification.

The Court also directed disclosure of relevant vaccination information, subject to applicable privacy considerations.

Relevance:

The judgment is important for digital vaccination records, health databases, vaccination certificates and compulsory health-monitoring policies.

It establishes that public-health objectives must be reconciled with bodily autonomy and constitutional rights.

Case 8: Maneka Gandhi v. Union of India (1978)

Supreme Court of India · (1978) 1 SCC 248

Legal principle:

Any procedure affecting personal liberty must be fair, just and reasonable rather than arbitrary or oppressive.

Relevance:

A digital biosurveillance system that restricts access to public services or imposes movement restrictions based on automated biological classifications must satisfy applicable constitutional requirements of fairness and non-arbitrariness.

Case 9: In Re: Pegasus Spyware Case (2021)

Supreme Court of India · (2021) 8 SCC 1

Facts:

Petitions raised allegations concerning the use of Pegasus spyware to monitor journalists, activists and other individuals.

Legal issue:

Whether allegations of unauthorised digital surveillance required independent judicial scrutiny.

Judgment:

The Supreme Court constituted an independent technical committee supervised by a former Supreme Court judge to investigate the allegations.

The Court emphasised that national security cannot be used as a blanket justification to avoid judicial examination.

Relevance:

Although this case was not specifically about biological surveillance, it is important for the governance of technology-assisted monitoring.

It supports independent technical investigation, institutional accountability and judicial supervision of surveillance concerns.

6. International Case Laws on Digital and Biological Surveillance

International judgments provide useful comparative principles for developing biosurveillance governance.

Case 10: S. and Marper v. United Kingdom (2008)

European Court of Human Rights · Applications Nos. 30562/04 and 30566/04

Facts:

The case involved the retention of fingerprints, cellular samples and DNA profiles of individuals who had been arrested but not convicted.

Legal issue:

Whether indefinite retention of biological identification information violated Article 8 of the European Convention on Human Rights.

Judgment:

The European Court of Human Rights found a violation of Article 8, which protects private and family life.

The Court considered the potentially intrusive nature of retaining DNA information and the absence of sufficient distinctions between convicted and unconvicted persons.

Relevance:

This judgment is highly relevant to:

National DNA databases.

Genetic surveillance.

Biological sample retention.

Genetic privacy.

Retention of information concerning innocent individuals.

It establishes an important comparative principle that biological information should not be retained indiscriminately without adequate justification.

Case 11: Big Brother Watch and Others v. United Kingdom (2021)

European Court of Human Rights · Applications Nos. 58170/13 and Others

Facts:

The case concerned large-scale electronic surveillance and the interception of communications by intelligence authorities.

Legal issue:

Whether bulk interception systems complied with privacy and freedom of expression protections.

Judgment:

The Grand Chamber identified deficiencies in the United Kingdom's bulk interception framework, including insufficient safeguards at important stages of surveillance.

Relevance:

The judgment provides comparative principles for:

Bulk biological information collection.

Large-scale health databases.

Inter-agency data sharing.

Independent authorisation.

End-to-end surveillance safeguards.

Case 12: R (Bridges) v. Chief Constable of South Wales Police (2020)

Court of Appeal of England and Wales · [2020] EWCA Civ 1058

Facts:

The case concerned the use of automated facial recognition technology by South Wales Police.

Legal issue:

Whether the deployment of facial recognition technology complied with privacy, data protection and equality requirements.

Judgment:

The Court of Appeal found that aspects of the police framework were insufficiently defined, including the selection of watchlists and locations where the technology could be deployed.

Relevance:

The judgment is useful for examining AI-based biometric surveillance and automated identification.

Its principles can inform governance of AI-powered health identification and biometric monitoring systems.

Case 13: Carpenter v. United States (2018)

United States Supreme Court · 585 U.S. 296 (2018)

Facts:

The case involved government access to historical cell-site location information held by telecommunications companies.

Legal issue:

Whether obtaining extensive historical location records constituted a search under the Fourth Amendment.

Judgment:

The Supreme Court held that government acquisition of the historical cell-site records at issue constituted a Fourth Amendment search and generally required a warrant supported by probable cause.

Relevance:

The decision is significant for understanding how the aggregation of individually generated digital records can reveal intimate patterns of personal life.

The same reasoning is relevant to location-linked health surveillance, although Carpenter is a US constitutional decision and does not directly govern Indian law.

7. Indian Legislative Framework Governing Digital Biosurveillance

Digital biosurveillance is governed by several overlapping areas of Indian law.

A. Digital Personal Data Protection Act, 2023

The Digital Personal Data Protection Act, 2023 is an important legislative instrument for regulating digital personal data.

It establishes a framework concerning:

Lawful processing of personal data.

Consent and permitted uses.

Obligations of data fiduciaries.

Security safeguards.

Individual rights.

Data protection enforcement.

Biometric and identifiable health information can fall within the definition of personal data when they relate to an identifiable individual.

An important distinction is that the Act does not create a separate category of sensitive personal data in the same manner as some earlier Indian data-protection proposals.

Current commencement position: The DPDP Act and Rules have a phased implementation schedule. As of 5 November 2026, the principal substantive processing obligations and individual-rights provisions scheduled for commencement 18 months after the November 2025 notification are not yet in force. Their scheduled commencement is 13 May 2027. Certain other provisions have already commenced or have different commencement dates.

MeitY+2

Therefore, it is important not to describe the entire substantive DPDP framework as already operational.

B. Information Technology Act, 2000

The Information Technology Act provides the broader legal framework for electronic information and cybersecurity.

Relevant provisions include:

Section 43: Unauthorised access and certain forms of damage to computer systems.

Section 66: Computer-related offences.

Section 72: Breach of confidentiality and privacy.

Section 72A: Disclosure of information in breach of lawful contract.

These provisions may become relevant where health databases are unlawfully accessed, biological information is disclosed or digital medical records are misused.

C. Epidemic Diseases Act, 1897

The Epidemic Diseases Act provides governmental powers to address dangerous epidemic diseases.

It enables governments to adopt special measures and regulations to prevent the spread of epidemic diseases.

In digital biosurveillance, these powers may intersect with:

Disease reporting.

Public-health monitoring.

Quarantine administration.

Digital contact tracing.

Outbreak investigation.

However, epidemic-control powers should not be interpreted as an unlimited authorisation for collecting unrelated personal information.

D. Disaster Management Act, 2005

The Disaster Management Act establishes institutional arrangements for disaster prevention, preparedness, mitigation and response.

During a public-health emergency, its provisions may support coordinated governmental action.

Digital surveillance systems used during emergencies must nevertheless remain subject to applicable constitutional requirements.

E. HIV and AIDS (Prevention and Control) Act, 2017

This legislation is especially important because it protects confidentiality concerning HIV-related information.

Its provisions address confidentiality, informed consent and restrictions on disclosure of HIV-related information, subject to legally recognised exceptions.

Relevance: Digital HIV databases must incorporate confidentiality protections and safeguards against discrimination.

F. Clinical Establishments and Medical Confidentiality Framework

The Clinical Establishments (Registration and Regulation) Act, 2010, where applicable, and professional medical ethics requirements contribute to the regulation of medical records and healthcare institutions.

These frameworks are relevant to the handling of patient information within digital hospital systems.

G. Biomedical Waste Management Rules, 2016

These Rules regulate the handling and disposal of biomedical waste.

They are relevant where biosurveillance programmes collect biological samples, diagnostic materials and infectious specimens.

They help address physical biological safety, although they do not independently establish a comprehensive digital-data protection framework.

8. Governance of AI-Based Biosurveillance

Artificial intelligence introduces new challenges because biological information may be analysed automatically to predict health risks and classify populations.

Consider an AI system that analyses:

Genetic information.

Medical histories.

Blood-test results.

Location information.

Disease exposure.

Behavioural health indicators.

The system may generate predictions about whether an individual is likely to develop a particular disease.

Such predictions can create legal problems if they are inaccurate, discriminatory or used beyond their original purpose.

Major governance requirements include:

A particularly important question concerns responsibility when an AI system incorrectly classifies an individual as infectious or genetically high-risk.

Depending on the circumstances, responsibility may involve the healthcare institution, software provider, data fiduciary, public authority or another legally responsible actor.

9. Institutional Accountability in Digital Biosurveillance

Effective governance requires clear allocation of responsibilities.

The institutional framework must prevent excessive concentration of surveillance powers.

It should also ensure that scientific authorities do not exercise unrestricted power over the collection and secondary use of personal biological information.

10. Major Legal Challenges in Digital Biosurveillance Governance

10.1 Mass collection of biological information

Governments may collect information from millions of individuals to identify disease patterns.

The legal difficulty arises when surveillance extends beyond the population or information reasonably necessary for public-health protection.

10.2 Genetic privacy and familial information

Genetic information does not concern only the individual who provides a DNA sample. It may also reveal information about biological relatives.

Consequently, genetic databases raise questions concerning:

Family privacy.

Genetic inheritance.

Consent for secondary use.

Law-enforcement access.

Commercial exploitation.

10.3 Function creep

Function creep occurs when information collected for one purpose is subsequently used for an unrelated purpose.

For example, information initially collected for infectious disease monitoring might later be used for employment screening or predictive policing.

10.4 Cross-border biological data transfers

International healthcare research and disease surveillance frequently involve transferring genetic and medical information between countries.

This creates conflicts involving:

Different privacy standards.

Foreign governmental access.

Research consent.

International data-transfer restrictions.

Jurisdiction over data breaches.

Ownership and control of biological samples.

10.5 Discrimination through biological profiling

Digital biosurveillance may produce discriminatory outcomes where individuals are classified according to genetic predisposition, disability or predicted health risks.

For example, an employer might improperly use genetic predictions to exclude an applicant from employment.

Such practices may raise constitutional, statutory and contractual issues.

10.6 Surveillance without meaningful transparency

Individuals may not know that their biological information is being collected, analysed or shared.

This creates an accountability problem because affected persons may have difficulty identifying the responsible authority or challenging an unlawful surveillance programme.

11. Proposed Framework for Digital Biosurveillance Governance

A comprehensive governance model should incorporate the following safeguards.

Seven pillars of responsible biosurveillance

Legal authorisation

Surveillance must be based on clear legal authority and defined public-health objectives.

Privacy protection

Identifiable biological information must receive appropriate protection.

Scientific accountability

Surveillance algorithms must undergo scientific validation and accuracy testing.

Independent supervision

Independent authorities must examine surveillance practices and compliance.

Transparency

Individuals should receive meaningful information about applicable surveillance practices.

Security and retention

Data must be protected against unauthorised access and retained only as legally justified.

Effective remedies

Individuals should have access to appropriate complaint procedures and judicial remedies.

12. Difference Between Digital Biosurveillance and Traditional Public-Health Surveillance

The important distinction is that digital biosurveillance can enable continuous, large-scale and automated analysis of biological information.

This increases the need for technological and constitutional safeguards.

13. Critical Legal Analysis

Digital biosurveillance creates a difficult relationship between collective public-health interests and individual constitutional freedoms.

The State has a legitimate responsibility to prevent epidemics, identify emerging diseases and protect vulnerable populations. However, this responsibility does not establish unlimited authority to collect, retain or disclose biological information.

Three important legal tensions emerge.

First: Public health versus privacy.

Public-health authorities may require certain information to identify disease outbreaks. Nevertheless, the collection must be restricted to what is legally justified and reasonably necessary.

Second: Technological efficiency versus constitutional accountability.

AI systems may identify biological risks faster than traditional medical investigations. However, automated predictions must not become unquestionable grounds for restricting individual freedoms.

Third: National security versus transparency.

Governments may rely on confidentiality to protect legitimate security interests. But secrecy should not eliminate meaningful oversight of surveillance powers.

The constitutional framework developed in Puttaswamy, together with the comparative principles in S. and Marper, Big Brother Watch and Bridges, provides a basis for evaluating these tensions.

One important limitation must be recognised: the comparative judgments do not create directly binding Indian legal rules. Their principles must be applied through the Indian Constitution and applicable legislation.

14. Important Case Laws: Quick Revision Table

15. Conclusion

Digital Biosurveillance Governance represents an emerging area of constitutional, public-health, biotechnology and data-protection law.

Its central objective is to ensure that biological information collected through digital technologies is used responsibly, lawfully and proportionately.

The Indian Supreme Court's decision in K.S. Puttaswamy v. Union of India (2017) provides the most important constitutional foundation because it recognises informational privacy as a fundamental right.

Other decisions, including Selvi, PUCL, Puttaswamy (Aadhaar) and Jacob Puliyel, provide additional principles concerning bodily autonomy, surveillance safeguards, biometric information and public-health decision-making.

Ultimately, a legitimate digital biosurveillance system must protect public health without turning biological information into an instrument of unrestricted governmental or commercial control.

The fundamental legal principle is that public-health protection and individual privacy must operate together under constitutional governance, scientific accountability and effective institutional oversight.

16. Research References and Primary Legal Materials

For further academic research, the following materials are particularly useful:

K.S. Puttaswamy v. Union of India (2017) – Constitutional privacy judgment.

Puttaswamy – Aadhaar judgment – Biometric identification and privacy.

The Surveillance State, Privacy and Criminal Investigation in India – Academic analysis of surveillance law.

The Surveillance Law Landscape in India – Surveillance safeguards and constitutional developments.

Digital Personal Data Protection Rules, 2025 – Official Gazette notification.

MeitY – DPDP Rules and implementation documents – Official legislative materials.

CCG Privacy High Court Case Tracker – Indian privacy jurisprudence.

Academic research note: Digital Biosurveillance Governance can be developed as a distinct research framework by synthesising constitutional privacy, public-health legislation, biotechnology regulation, AI accountability and digital data protection. It should not be presented as an already established standalone doctrine of the Supreme Court of India.