263 Ratna Sisodiya, Rachana Choudhary e Surendra Singh Bhati 1. India’s Aadhaar System: India’s Aadhaar system, a biometric identification program, has faced criticism for privacy breaches and security vulnerabilities. Instances of Aadhaar data leaks and misuse have raised concerns about the government’s ability to safeguard citizens’ personal information31. Additionally, the mandatory linking of Aadhaar to various services has been challenged in courts on grounds of violating privacy rights32. 2. Pakistan’s Surveillance Laws: Pakistan has implemented surveillance laws such as the Pakistan Telecommunication (Re-organization) Act, which grants broad powers to government agencies for intercepting communications and monitoring online activities. Human rights organizations have criticized these laws for enabling arbitrary surveillance and infringing on citizens’ right to privacy33. Instances of misuse of surveillance powers have also been reported, raising concerns about accountability and transparency. 3. Sri Lanka’s Surveillance Practices: Sri Lanka has faced scrutiny over its surveillance practices, particularly in the context of counterterrorism measures. The Prevention of Terrorism Act (PTA) and emergency regulations have been criticized for granting excessive surveillance powers to security forces, leading to arbitrary arrests and violations of due process rights34. Reports have highlighted instances of government surveillance targeting journalists, activists, and minority groups, undermining freedom of expression and dissent. 31 The Wire. (2021). The Aadhaar Leaks That Exposed India’s Patchy Data Protection Laws. Retrieved from https://thewire.in/government/ aadhaar-leaks-data-protection-laws-india 32 The Quint. (2018). Aadhaar: A Timeline of the World’s Largest Data Breach. Retrieved from https://www.thequint.com/news/india/aadhaar-time line-data-breach-uidai 33 Digital Rights Foundation. (2020). Pakistan’s Surveillance Laws and Policies. Retrieved from https://digitalrightsfoundation.pk/surveillance -laws-and-policies-in-pakistan/ 34 Human Rights Watch. (2020). Sri Lanka: End Police Surveillance of Activists. Retrieved from https://www.hrw.org/news/2020/06/22/sri-lan ka-end-police-surveillance-activists
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