1. Introduction

The concept of a “Zero-Knowledge State” in energy governance can be understood as a model of governance in which the State collects, processes, and uses only the minimum information necessary to regulate the energy sector, while protecting citizens' privacy, confidential commercial information, and sensitive infrastructure data.

However, an important legal clarification is necessary: “Zero-Knowledge State” is not a universally established or independently recognized doctrine of energy law. It is better understood as an emerging governance concept drawing upon privacy law, constitutional rights, cybersecurity, data minimisation, and zero-knowledge cryptographic technologies.

In energy governance, this concept raises a fundamental question:

Can the government ensure energy security, regulate electricity markets, prevent fraud, and promote renewable energy without unnecessarily accessing or exposing the personal and commercially sensitive data of citizens and energy companies?

The answer is potentially yes. Privacy-preserving technologies and legally limited data access can enable the State to verify compliance without acquiring complete knowledge of the underlying information.

This discussion examines the concept through constitutional principles, Indian energy legislation, relevant judicial decisions, and comparative international jurisprudence.

2. Meaning of a Zero-Knowledge State

A. General meaning

A Zero-Knowledge State is a governance model in which public authorities do not automatically possess unlimited knowledge of individuals, households, businesses, or energy infrastructure merely because they regulate them.

Instead, the State relies on three foundational principles:

Data minimisation: Collect only the data necessary for a legitimate regulatory purpose.

Purpose limitation: Use information only for the purpose for which it was lawfully collected.

Privacy-preserving verification: Verify whether a legal or regulatory condition has been satisfied without necessarily obtaining all the underlying information.

For example, an electricity regulator may need to establish that a power generator complies with renewable energy obligations. It might be possible to verify the required quantity of renewable electricity through certified meter readings, digital attestations, or cryptographic proofs rather than receiving unrestricted access to every consumer's detailed electricity usage records.

B. The cryptographic meaning of zero knowledge

In computer science, a zero-knowledge proof is a cryptographic protocol through which one party (the prover) demonstrates to another party (the verifier) that a statement is true without revealing the underlying secret information.

A conventional zero-knowledge proof has three principal properties:

Completeness: If the statement is true and the protocol is correctly followed, the verifier accepts the proof.

Soundness: A party should not be able to convince the verifier of a false statement, except with negligible probability.

Zero knowledge: The proof reveals no additional information about the secret beyond what is implied by the statement being verified.

Consider a household that uses a smart electricity meter. A regulator may need to confirm that the household qualifies for a particular electricity subsidy. A privacy-preserving system could prove that the household satisfies the eligibility conditions without disclosing its entire consumption history.

The precise design matters: if the regulator must verify income, household composition, or another eligibility condition, the proof must reliably establish the relevant condition. Cryptography alone cannot guarantee that the original data are accurate.

C. Zero-knowledge technology versus Zero-Knowledge State

Thus, a Zero-Knowledge State does not mean that the State knows nothing. It means that the State should know only what is necessary, lawful, and proportionate to its public functions, with stronger privacy-preserving methods used where practical.

3. Why is the Zero-Knowledge State relevant to energy governance?

Modern energy systems increasingly depend on digital information. Smart meters, electricity distribution networks, renewable energy certificates, battery systems, electric vehicles, and demand-response programmes generate large volumes of data.

The challenge is that the same information that improves energy efficiency can also reveal sensitive details about individuals and businesses.

A. Smart meters and household privacy

Smart meters record electricity consumption, sometimes at frequent intervals. Detailed patterns can help infer when occupants are home, their daily routines, or which appliances they use. A Zero-Knowledge approach would restrict access to detailed readings unless they are genuinely needed.

B. Grid security and critical infrastructure

Electricity networks contain sensitive information about substations, control systems, network vulnerabilities, and demand patterns. Governance must enable regulators to inspect and secure these systems without making sensitive operational information universally accessible.

C. Renewable energy compliance

Regulators need to establish whether generators meet renewable purchase obligations, whether electricity is properly accounted for, and whether subsidies are justified. Cryptographic verification could establish compliance while reducing disclosure of unrelated business records.

D. Electricity subsidies and consumer welfare

Governments need to identify eligible beneficiaries and prevent fraudulent claims. Privacy-preserving eligibility checks can reduce the need to create extensive, centralised databases of household information.

Research on European electricity law similarly identifies the tension between the operational advantages of smart metering and the privacy risks associated with detailed consumption data.

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4. Constitutional foundations in India

India does not expressly recognise a constitutional doctrine called the “Zero-Knowledge State.” Nevertheless, several constitutional principles support aspects of this model.

A. Article 21: Right to life, liberty and privacy

Article 21 of the Constitution provides that no person shall be deprived of life or personal liberty except according to procedure established by law.

The Supreme Court has interpreted this provision to protect privacy, dignity, and personal autonomy. These protections are relevant when State agencies, electricity distribution companies, or other entities process information that can reveal intimate aspects of a person's life.

In energy governance, Article 21 provides a constitutional basis for questioning unnecessary collection, excessive retention, or disproportionate use of identifiable electricity-consumption data.

B. Article 14: Equality and non-arbitrariness

Article 14 protects equality before the law and equal protection of the laws.

Energy-data systems can create arbitrary outcomes when algorithms classify consumers as suspicious, deny subsidies, or trigger enforcement without adequate safeguards.

A privacy-preserving governance model should therefore provide:

Clear and objective criteria for data collection.

Equal treatment of similarly situated consumers.

Reasons for adverse decisions.

Mechanisms to challenge incorrect records and automated assessments.

C. Article 19: Freedom and individual autonomy

Article 19 protects specified freedoms, including freedom of speech and expression under Article 19(1)(a), subject to constitutional restrictions.

Excessive monitoring can potentially chill lawful behaviour, particularly when people believe that their activities are continuously observed. However, not every collection of electricity data automatically violates Article 19. A claimant must establish the relevant constitutional infringement, and any restriction must satisfy the applicable legal requirements.

D. Directive Principles and public interest

Articles 38, 39, 48A and 51A(g) inform the broader constitutional framework concerning welfare, distribution of resources, environmental protection, and environmental responsibility.

Energy governance must balance these public interests with privacy and individual rights. Clean energy, affordable electricity, and grid reliability are legitimate governmental objectives, but they do not automatically justify unlimited access to personal information.

The central constitutional principle is that the State's legitimate objective does not eliminate the requirement to justify the means used to achieve it.

5. Important case laws

The following decisions are particularly useful. Some directly establish principles of privacy and State surveillance; others provide comparative guidance for digital energy regulation. They should not be misrepresented as judgments that specifically established a Zero-Knowledge State doctrine.

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

Supreme Court of India · Nine-judge Constitution Bench · (2017) 10 SCC 1

Facts: The litigation arose in the context of Aadhaar and the collection and use of residents' demographic and biometric information. The question referred to the nine-judge Bench was whether privacy is a constitutionally protected fundamental right.

Judgment: On 24 August 2017, the Supreme Court unanimously recognised privacy as a fundamental right protected by the Constitution, particularly under Article 21 and the freedoms guaranteed by Part III.

The judgment recognised that privacy includes dimensions such as bodily privacy, informational privacy, dignity, and individual autonomy.

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Relevance to energy governance:

Smart-meter records can reveal information about a person's private life.

State-mandated energy-data collection must be evaluated against constitutional privacy protections.

The fact that data collection serves a public purpose does not automatically make every form of collection lawful.

A privacy-preserving system may help reduce unnecessary disclosure and surveillance.

Legal significance: Puttaswamy provides the strongest Indian constitutional foundation for a Zero-Knowledge approach to energy governance.

Importantly, the case does not prohibit all State collection of personal data. It requires constitutional justification and appropriate safeguards.

Case 2: K.S. Puttaswamy (Retd.) v. Union of India (2018) — Aadhaar judgment

Supreme Court of India · Constitution Bench · (2019) 1 SCC 1

Facts: The Court examined the constitutional validity of the Aadhaar framework, including the collection and use of biometric information and the use of Aadhaar authentication for different purposes.

Judgment: In its judgment of 26 September 2018, the majority upheld Aadhaar's statutory framework in substantial part while invalidating or restricting certain provisions and uses. The judgment addressed proportionality, the statutory basis for collection, privacy, and the scope of mandatory authentication.

Justice D.Y. Chandrachud's dissent raised particularly strong concerns about informational privacy, data minimisation, surveillance, and exclusion arising from authentication failures. The majority and dissent should be distinguished when citing their respective conclusions.

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Relevance to energy governance:

Suppose a government requires Aadhaar authentication to provide electricity subsidies. The Aadhaar judgment demonstrates why the legal basis, purpose, scope, and safeguards of such a requirement matter.

A Zero-Knowledge-inspired design could allow a system to establish that a claimant meets an eligibility condition without unnecessarily sharing identity data with every agency involved.

However, such a design must still comply with the applicable Aadhaar legislation and rules; cryptography cannot independently authorise an otherwise unlawful use of identity information.

Legal principle: Welfare efficiency and privacy must be reconciled through lawful and proportionate institutional arrangements.

Case 3: Kharak Singh v. State of Uttar Pradesh (1963)

Supreme Court of India · AIR 1963 SC 1295

Facts: The case challenged police surveillance measures imposed under police regulations, including domiciliary visits and surveillance of individuals considered suspects.

Judgment: The Supreme Court struck down the challenged provision authorising domiciliary visits at night. The majority did not then recognise a general fundamental right to privacy in the broad form subsequently established in Puttaswamy. Justice Subba Rao's dissent advanced a more expansive understanding of privacy and personal liberty.

Relevance to energy governance:

The case is historically important because it concerns the relationship between State surveillance and individual liberty.

In a digital energy system, continuous monitoring of household consumption may create a comparable concern where data are used to observe personal behaviour rather than to perform a legitimate energy-sector function.

The analogy is limited: the case concerned police surveillance, not electricity metering. Its modern significance must be read alongside the later constitutional ruling in Puttaswamy.

Case 4: People's Union for Civil Liberties v. Union of India (1997)

Supreme Court of India · (1997) 1 SCC 301

Facts: The case concerned telephone tapping and the safeguards required when the State intercepts private communications.

Judgment: The Supreme Court held that telephone tapping constitutes a serious invasion of privacy and laid down procedural safeguards governing interception under the then-applicable legal framework.

Relevance to energy governance:

Electricity consumption records are not communications content, so telephone interception law cannot simply be applied to smart meters. Nevertheless, the case illustrates a broader rule-of-law principle: intrusive State powers require legal authority and safeguards against arbitrary exercise.

Applied by analogy, access to highly granular household energy data should be governed by defined purposes, access controls, accountability, and independent oversight.

Legal principle: Legitimate public objectives do not justify unregulated surveillance powers.

Case 5: Anuradha Bhasin v. Union of India (2020)

Supreme Court of India · (2020) 3 SCC 637

Facts: The case concerned restrictions on internet access in Jammu and Kashmir, including the publication and review of orders imposing those restrictions.

Judgment: The Supreme Court held that freedom of speech and expression and the freedom to practise a profession through the internet receive constitutional protection under the applicable provisions of Article 19. It required publication of relevant restriction orders and meaningful review of restrictions, and held that indefinite suspension of internet services is impermissible.

Relevance to energy governance:

Digital energy systems increasingly depend on communications networks, remote monitoring, and online access to services. Restrictions or technological interventions that affect electricity-related digital services may therefore raise questions about legality, necessity, proportionality, and review, depending on their nature and impact.

The judgment is not a smart-grid privacy case. Its value is in demonstrating that digital governance measures affecting protected rights must be legally justified and subject to review.

Case 6: Modern Dental College and Research Centre v. State of Madhya Pradesh (2016)

Supreme Court of India · (2016) 7 SCC 353

Facts: The case concerned State regulation of admissions and fee structures in private professional educational institutions.

Judgment: The Supreme Court discussed proportionality in evaluating restrictions on constitutional freedoms and the legitimacy of regulatory measures.

Relevance to energy governance:

The proportionality framework can help evaluate measures such as compulsory smart-meter deployment, extensive data collection, mandatory data sharing, or digital monitoring requirements.

A regulator should ask:

Is the measure authorised by law?

Does it pursue a legitimate objective?

Is it rationally connected to that objective?

Is there a less intrusive, reasonably effective alternative?

Are the benefits proportionate to the interference with rights?

The case does not specifically concern informational privacy or energy data. It is relevant for the broader constitutional method used to assess regulatory restrictions.

Case 7: Digital Rights Ireland Ltd v. Minister for Communications (2014)

Court of Justice of the European Union · Joined Cases C-293/12 and C-594/12 · ECLI:EU:C:2014:238

Facts: The cases challenged European legislation requiring the retention of telecommunications data for potential law-enforcement access.

Judgment: The Court of Justice invalidated the Data Retention Directive because the interference with fundamental rights to privacy and personal-data protection was broad and insufficiently limited by adequate safeguards.

Relevance to energy governance: Although the case concerned telecommunications, its reasoning is relevant when governments propose collecting extensive smart-meter records for unspecified future uses. The sensitivity of a dataset depends not only on its individual entries but also on the inferences that can be drawn from it.

A Zero-Knowledge approach could reduce the amount of raw data available to regulators, while access to identifiable information could be restricted to specifically authorised purposes.

Important qualification: The judgment did not prohibit all data retention. It rejected the particular framework before the Court.

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Case 8: Netz Niederösterreich GmbH — Case C-468/24

Court of Justice of the European Union · Preliminary reference · Status checked October 2026

This case is particularly relevant to smart-meter governance.

Issue: The Austrian proceedings concern whether an electricity customer can require a conventional meter instead of a smart meter, in light of EU electricity-market legislation and data-protection requirements.

The questions include the relationship between the deployment of smart meters, customers' preferences, and the protection of consumption data.

The Court's official case record lists an Advocate General's Opinion dated 11 December 2025. The materials located for this discussion do not establish a final judgment in the case, so it should be treated as a pending reference rather than a decided precedent.

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Relevance to Zero-Knowledge governance:

Can energy-system objectives be achieved without collecting detailed household consumption records?

Should customers have meaningful choices concerning data collection and meter configuration?

Can privacy-preserving configurations protect consumers while maintaining essential grid functions?

These are directly relevant policy questions, although the final legal answer depends on the applicable EU legislation and the eventual resolution of the proceedings.

6. Indian statutory framework

The Zero-Knowledge State concept can be translated into practice through existing energy, information-technology, and data-protection laws.

A. Electricity Act, 2003

The Electricity Act provides the central statutory framework for electricity generation, transmission, distribution, trading, and regulation in India.

Relevant institutional features include:

The Central Electricity Regulatory Commission (CERC) and State Electricity Regulatory Commissions (SERCs), which exercise regulatory functions within their respective jurisdictions.

The Central Electricity Authority (CEA), which performs technical and planning functions under the Act.

Distribution licensees, which meter electricity consumption, bill consumers, and maintain relevant operational records.

Statutory powers concerning electricity metering, standards, tariffs, and regulatory compliance.

The Act does not establish a general right to zero-knowledge processing. Nevertheless, its regulatory objectives can be pursued through systems that limit the circulation of personal data beyond what is necessary for metering, billing, grid operation, and lawful regulatory oversight.

B. Digital Personal Data Protection Act, 2023

The Digital Personal Data Protection Act, 2023 is particularly relevant to digitally identifiable consumer information. Its stated purpose is to recognise both individuals' interest in protecting personal data and the need to process such data for lawful purposes.

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Its relevance to energy governance includes:

Defining the lawful basis for processing personal data.

Regulating the responsibilities of entities that determine the purposes and means of processing.

Establishing safeguards and obligations concerning personal-data processing.

Providing a framework for individual rights and regulatory accountability.

Commencement qualification: The Act provides for commencement on dates appointed by the Central Government, and different provisions can commence at different times. The official India Code text records a phased commencement schedule beginning in November 2025. Therefore, the applicable provision and commencement date must be checked before asserting that a particular duty or right is currently enforceable.

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The Act does not require every energy system to use zero-knowledge cryptography. Rather, privacy-preserving technology may help an organisation meet applicable legal requirements where the technology is appropriate to the processing activity.

C. Information Technology Act, 2000

The Information Technology Act, 2000 provides a statutory framework for electronic records, electronic transactions, and specified cybersecurity-related matters.

Section 43A historically addressed compensation for failure to protect sensitive personal data or information by a body corporate, subject to its conditions. Its current legal operation must be assessed alongside the commencement and transitional provisions of the DPDP Act and related amendments. It should not automatically be described as an independently operative general privacy remedy in every case.

D. Information Technology Rules and cybersecurity requirements

Applicable information-security requirements, including the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 where relevant, and directions issued under the IT Act, may affect how energy-sector entities secure information.

For energy infrastructure, cybersecurity also requires protection against unauthorised control of equipment, disruption of supply, manipulation of meter readings, and attacks on grid-management systems.

The goal is not merely to conceal data. It is to ensure that the right people can access the right information for legitimate purposes without exposing the entire system to misuse.

7. How can a Zero-Knowledge State work in energy governance?

A practical model combines legal restrictions, privacy-enhancing technology, and independent oversight.

Stage 1: Consumer or generator data

Consumption readings, generation records, subsidy eligibility or renewable-energy certificates

Stage 2: Local verification

A secure meter, utility system or authorised verifier checks the relevant conditions

Stage 3: Minimal proof or report

The regulator receives a proof of compliance, an aggregate statistic or a limited attestation

Stage 4: Regulatory decision

The regulator approves a claim, verifies an obligation or initiates a lawful investigation

This architecture is illustrative rather than a legally prescribed Indian system. Its effectiveness depends on secure implementation, accurate source data, appropriate cryptographic protocols, and a lawful basis for processing.

Example 1: Renewable Purchase Obligations

Suppose an electricity distribution company must demonstrate compliance with an applicable Renewable Purchase Obligation (RPO).

Under a conventional system, the regulator may examine detailed generation records, electricity purchases, energy certificates, and supporting financial documents.

A privacy-preserving alternative could work as follows:

The distribution company supplies authenticated records to a verification system.

The system checks the relevant reporting period, eligible renewable-energy quantities, and applicable compliance formula.

A cryptographic proof or independently audited attestation confirms that the obligation has been met.

The regulator receives the proof and retains the power to request underlying records when legally justified.

The regulator does not necessarily need unrestricted access to every commercial transaction merely to verify the final compliance calculation.

However, a zero-knowledge proof cannot establish that a generator's original meter readings are truthful unless the metering and data-authentication process is also reliable.

Example 2: Smart-meter electricity consumption

Consider a household whose smart meter records electricity consumption every 15 minutes.

A distribution company needs consumption information for accurate billing, while the system operator may need more detailed information for forecasting or managing grid demand.

A Zero-Knowledge-inspired system could distinguish between these purposes:

The last row is a governance objective, not an absolute legal prohibition covering every conceivable use. Actual access depends on applicable law, purpose, necessity, and safeguards.

Example 3: Electricity subsidy distribution

Suppose a government offers an electricity subsidy to households satisfying specified eligibility conditions.

Instead of circulating complete identity and household records among multiple departments, the system could issue a verifiable eligibility credential. A distribution company would then verify that the credential is valid and that the subsidy conditions are met.

This approach could reduce unnecessary disclosure, provided that the eligibility credential is trustworthy, the scheme's legal requirements are met, and consumers are not unfairly excluded by technological failures.

8. Major benefits of Zero-Knowledge energy governance

1. Protection of informational privacy

Consumers gain stronger protection against unnecessary access to detailed electricity-use patterns and associated behavioural inferences.

2. Reduced exposure in data breaches

Limiting the volume of centrally held identifiable data can reduce the consequences of unauthorised access. It does not eliminate cybersecurity risks.

3. Better regulatory accountability

Standardised proofs and audit trails can make compliance verification more consistent and easier to review.

4. Support for the energy transition

Privacy-preserving analytics can help enable smart grids, renewable-energy integration, and demand response without requiring unrestricted disclosure of every consumer's data.

5. Greater public trust

Transparent data-access rules can make consumers more confident that digital energy infrastructure serves legitimate public purposes rather than becoming an instrument of excessive surveillance.

9. Challenges and limitations

A Zero-Knowledge State is not a complete solution to the problems of digital energy governance.

Technical complexity: Cryptographic proofs may be costly to develop, maintain, and verify, particularly in large, heterogeneous energy systems.

Incorrect source data: A mathematically valid proof may still rely on false or manipulated meter readings.

Cybersecurity threats: Smart meters, control systems, identity credentials, and verification software remain vulnerable to attacks.

Regulatory investigation: Auditors and regulators may sometimes need access to underlying records to investigate fraud, unsafe operations, or deliberate non-compliance.

Algorithmic exclusion: Faulty credentials, inaccessible systems, or erroneous automated decisions may deny consumers subsidies or services.

Institutional concentration: Even if one regulator receives limited information, another agency or private contractor may retain extensive data unless the entire information-sharing framework is properly designed.

Public accountability: Zero-knowledge proofs do not replace transparency about government policy, regulatory decisions, public expenditure, or the reasons for enforcement action.

A particularly important distinction is that zero knowledge about personal data does not mean zero transparency about government conduct. Public authorities must remain accountable for how they exercise power.

10. A proposed legal framework for India

India could develop a privacy-preserving energy-governance framework through sector-specific regulations, technical standards, and coordinated data-protection requirements.

These are policy recommendations rather than a statement that every measure is already required under Indian law.

Implementation could involve the Ministry of Power, the CEA, CERC, SERCs, distribution licensees, and the relevant data-protection authorities, each acting within its statutory powers.

11. Critical evaluation: Is the Zero-Knowledge State desirable?

The concept offers an important response to the expansion of digital government. Energy governance needs reliable information to ensure electricity supply, monitor compliance, plan infrastructure, and facilitate decarbonisation. Yet the availability of data does not automatically justify unrestricted collection or access.

The constitutional reasoning in Puttaswamy, the surveillance safeguards discussed in PUCL, and the proportionality principles reflected in Modern Dental College provide useful foundations for evaluating privacy-preserving energy systems.

At the same time, the State cannot fulfil every regulatory function without knowledge. Electricity theft, market manipulation, grid failures, and safety violations may require access to detailed records. A system that prevents all access could undermine accountability and public welfare.

The appropriate model is therefore selective, justified, and accountable State knowledge, supported by technology that reduces unnecessary disclosure without obstructing legitimate regulatory functions.

12. Conclusion

The Zero-Knowledge State in energy governance is best understood as a proposed model of privacy-preserving, technologically enabled, and constitutionally accountable regulation—not as a settled legal doctrine.

Its principal objective is to reconcile three requirements:

Energy security and regulatory effectiveness: The State must be able to ensure reliable supply, enforce obligations, and protect critical infrastructure.

Individual privacy and autonomy: Consumers should not be subjected to unnecessary surveillance merely because energy systems generate detailed personal data.

Transparency and accountability: Public authorities must remain answerable for their decisions, expenditures, and exercise of statutory powers.

The most relevant Indian precedent is Justice K.S. Puttaswamy (Retd.) v. Union of India (2017), which establishes the constitutional significance of privacy. The subsequent Aadhaar judgment, PUCL, and other proportionality and surveillance decisions provide further guidance, although none directly creates a Zero-Knowledge State doctrine in energy law.

Ultimately, the objective is not to make the State ignorant. It is to ensure that the State possesses the information it needs to govern energy systems effectively, while preventing unnecessary collection, disclosure, and misuse of information about the people those systems serve.

References for further study

Constitution of India — Articles 14, 19 and 21.

Electricity Act, 2003.

Digital Personal Data Protection Act, 2023, including its applicable commencement notifications and rules.

Justice K.S. Puttaswamy (Retd.) v. Union of India, (2017) 10 SCC 1.

K.S. Puttaswamy (Retd.) v. Union of India, (2019) 1 SCC 1.

Kharak Singh v. State of Uttar Pradesh, AIR 1963 SC 1295.

People's Union for Civil Liberties v. Union of India, (1997) 1 SCC 301.

Anuradha Bhasin v. Union of India, (2020) 3 SCC 637.

Modern Dental College and Research Centre v. State of Madhya Pradesh, (2016) 7 SCC 353.

Digital Rights Ireland Ltd v. Minister for Communications, Joined Cases C-293/12 and C-594/12, ECLI:EU:C:2014:238.

Directive (EU) 2019/944 on common rules for the internal market for electricity and Regulation (EU) 2016/679 (GDPR), for comparative analysis.

For academic writing, the most defensible thesis is that the Zero-Knowledge State is a normative and technological extension of privacy, proportionality, data minimisation, and accountable energy regulation, rather than a doctrine already expressly recognised by the courts.