IN THE SUPREME COURT OF INDIA

EXTRA ORDINARY ORIGINAL JURISDICTION

WRIT PETITION (CIVIL) NO. ________ OF 2024

(P.I.L) PUBLIC INTEREST LITIGATION

(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF:

SOUNDARYA D N ...PETITIONER

Versus

UNION OF INDIA ...RESPONDENT

PAPER BOOK

(FOR KINDLY SEE INSIDE)

PETITIONER IN PERSON – SOUNDARYA D N

 FORMAT OF INDEX

[Link]. Particulars of Document Page no.

1 Office Report on Limitation

2 Synopsis & List of Dates.

3 Writ Petition with Affidavit.

4 APPENDIX : Article 32 Constitution of

India.

5 ANNEXURE - A
 IN THE SUPREME COURT OF INDIA

EXTRA ORDINARY ORIGINAL JURISDICTION

WRIT PETITION (CIVIL) NO. ________ OF 2024

(P.I.L) PUBLIC INTEREST LITIGATION

(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF:

SOUNDARYA D N ...PETITIONERS

Versus

UNION OF INDIA ...RESPONDENT

Office Report on Limitation

1. The petition is within time.

2. Since this petition addresses the urgent and ongoing issue of

AI-driven behavioral advertising violating citizens' privacy
rights, there is no specific order being challenged, and the
timeline for filing is not constrained by procedural deadlines.

BRANCH OFFICER

New Delhi

Dated:- 5. 12. 2024

SYNOPSIS

The Petitioner files this writ petition under Article 32 of the

Constitution of India to challenge the unethical and
unconstitutional practices of AI-driven behavioral advertising,
which use advanced algorithms and consumer data to influence
decision-making processes. These techniques manipulate
personal autonomy, violate the Right to Privacy under Article
21, and promote discriminatory practices that contravene Article
14, as well as existing data protection legislation.

The concept of privacy of mind is expanded here to include the

privacy of one's behavioral and psychological processes, which
are integral to forming thoughts and personal decisions. The
current regulatory framework fails to provide adequate
protection, and general legal principles must be supplemented
with specific provisions to prohibit manipulative practices in
advertising.

Modern society, driven by profit, has adopted new techniques to

increase the sale of goods and services. Companies increasingly
employ specialized researchers and advanced technologies to
analyze consumer behavior, evaluate the impact of marketing
strategies, and optimize their effectiveness. Within the realm of
marketing, the use of AI and machine learning to influence
consumer choices has become prevalent, known as AI-driven
behavioral advertising.

Experts have raised ethical concerns about such techniques. As

William Safire, Chairman of the Dana Foundation, remarked,
"The ethics of technological influence on human behavior hit
home as no other research does. It delves into our consciousness
—our very sense of self—and this is central to our being."
Behavioral advertising, much like brain science, manipulates our
individuality, intelligence, and decision-making processes,
raising serious questions about its compatibility with
fundamental rights.

Within the constitutional framework, autonomy is protected as a

fundamental right under Part III of the Constitution of India.
Article 19 guarantees every citizen the right to:

- (a) Freedom of speech and expression, and

- (b) Move freely throughout the territory of India.

Article 21 states, “No person shall be deprived of his life or

personal liberty except according to procedure established by
law.” Together, these Articles protect the right to autonomy and
privacy, which includes the freedom to make choices without
external manipulation. The practice of AI-driven behavioral
advertising violates these constitutional protections by using
intrusive methods to control consumer behavior.

In 1997, the Supreme Court of India pronounced its judgement in

the case People’s Union for Civil Liberties (PUCL) Vs Union of
India (SC, 1997), which laid the groundwork for the right to
privacy in the context of telephonic surveillance (i.e. wiretaps)
and constitutional freedoms. In the landmark judgment KS
Puttaswamy v. Union of India (2017), the Supreme Court
recognized the right to privacy as intrinsic to the right to life and
liberty under Article 21. Furthermore, in Vinit Kumar v. Central
Bureau of Investigation (2019), the Bombay High Court
restricted the state's surveillance powers, emphasizing the
principle that individual privacy cannot be compromised without
a legitimate public interest. These principles are directly
applicable to the present issue of AI-driven advertising, which
intrudes upon individual autonomy without adequate
justification. On 24TH August 2017, a nine-judge bench of the
Supreme Court of India declared privacy as a fundamental right
protected under the Indian Constitution (Privacy Judgement). The
Supreme Court while holding the right to privacy as an intrinsic
part of the right to life and personal liberty, and informational
privacy as a facet of the right to privacy; highlighted the need for
government to examine and enforce a robust regime for data
protection.

Advertisement means announcement, demonstration or other

presentation disseminated partially with communication media
that aim at promoting entrepreneurial activity and in particular
supports the consumption or sale of goods, construction, lease or
sale of property, sale or use of right or obligations, supports the
provision of services or promotion of trademark, unless stated
otherwise.

The growing use of AI-driven behavioral advertising raises

serious concerns about privacy violations, especially related to
the collection of biometric data without user consent. The Patel
v. Facebook, Inc. (2020) judgment highlights this issue, where
Facebook’s use of facial recognition technology to create face
templates without explicit consent violated privacy rights under
Article 21 of the Constitution. The case emphasizes that
individuals have a fundamental right to control their biometric
data, and such data misuse must be regulated.

Additionally, companies like Google, Facebook, and LinkedIn

use cookies, tracking pixels, and other tools to monitor user
behavior without proper consent. These practices, which violate
privacy laws, manipulate consumer decisions. The attached
privacy policies (Annexure A) expose the widespread misuse of
personal data for commercial gain, reinforcing the need for
judicial intervention to protect individual privacy and regulate
such invasive technologies.

India currently lacks a comprehensive regulatory framework

to address the ethical challenges posed by AI in advertising.
Existing laws, such as the Consumer Protection Act, 2019,
prohibit unfair trade practices but do not adequately regulate
algorithmic manipulation. Unfair Commercial Practice in
advertising is prohibited in section 24 of the Act ( Restrictions of
advertisement and prohibition as to uniform trade practices).
The absence of unified legislation leaves consumers vulnerable
to exploitation by powerful corporations.

Given the rapid advancement of AI technologies and their

increasing application in advertising, there is an urgent need for
judicial intervention to protect constitutional rights. A balance
must be struck between enabling innovation and
 safeguarding individual autonomy and privacy. Courts should
provide clear guidelines to address the ethical and legal
implications of these technologies, ensuring that the interests of
businesses do not override fundamental rights.

LIST OF DATES AND EVENTS

1986 The Consumer Protection Act, 1986 is in place to hold

manufacturers accountable for production unsafe
goods.

1997 People’s Union for Civil Liberties v. Union of India

laid groundwork for the right to privacy in the context
of telephonic surveillance and constitutional freedom.

2003 Article 29. Data Protection Working Party. Working

document on Biometrics, European Commission.

2005 The Committee on Science and Law.

Neuroprivacy and the legal implications of brain

imaging. Record of the

Association of the Bar of the City of New York. Vol.60

2007 Article 29, Data Protection Working

Party. Opinion 4/2007 on the concept of personal Data,

European Commission.

2008 Illinois became the first state to enact a biometric data

 privacy law.

2017 KS Puttaswamy v. Union of India,

Privacy is the ultimate expression of the sanctity of the

individual. The Supreme

Court affirmed the reasoning and judgement given in

the PUCL Case.

2018 Personal Data Protection Bill, 2018. Constituted

committee of experts under chairmanship of Justice
B.N Srikrishna.

2019 The Consumer Protection Act, 2019 has been enacted

with a view to widen the scope of consumer rights and
cover the field of e-commerce, direct selling,
teleshopping and other multi levels of marketing in the
age of digitization.

2019 Vinit Kumar v. Central Bureau of

Investigation and Ors. Orders that directed interception

of his telephone class on the grounds that such orders
were ultra-vires of section 5(2) of the IT Act.

2020 Patel v. Facebook, Inc., 2020 The Facebook BIPA

(Biometric Information Privacy Law) class action
lawsuit Patel Vs Facebook, Inc. reached a conclusion
when Facebook agreed to a $650 million settlement.
 IN THE SUPREME COURT OF INDIA

EXTRA ORDINARY ORIGINAL JURISDICTION

WRIT PETITION (CIVIL) NO. ________ OF 2024

(P.I.L) PUBLIC INTEREST LITIGATION

(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF:

SOUNDARYA D N ...PETITIONERS

Versus

UNION OF INDIA ...RESPONDENT

WRIT PETITION UNDER ARTICLE 32 OF

THECONSTITUTION OF INDIA SEEKING A WRIT OR
ORDER OR DIRECTION IN THE NATURE OF
MANDAMUS DECLARING AI-DRIVEN BEHAVIORAL
ADVERTISING AS ILLEGAL, UNCONSTITUTIONAL
FOR BEING VIOLATIVE OF ARTICLE 14, ARTICLE 19
& ARTICLE 21 (RIGHT TO PRIVACY) OF THE
CONSTITUTION OF INDIA, AND PASS SUCH FURTHER
ORDER AS THIS HON’BLE COURT MAY DEEM
APPROPRIATE TO PROTECT THE FUNDAMENTAL
RIGHTS OF THE CITIZENS OF INDIA.
PETITIONER ITSELF: SOUNDARYA D N

To,

The Hon'ble Chief Justice of India

& His Companion Judges of this Hon'ble Court

The Writ Petition

of the Petitioner

Humble civil appeal in the interest of public.

MOST RESPECTFULLY SHOWETH:

1. That the petitioner is filing the Civil Writ Petition in Public

Interest under Article 32 of the Constitution of India, praying for
a writ, order, or direction in the nature of mandamus declaring
the practice of AI-driven behavioral advertising as illegal and
unconstitutional for being violative of Articles 14, 19(d), and 21
of the Constitution of India. These practices manipulate
consumer autonomy, violate the Right to Privacy, and promote
unfair trade practices. The petitioner also seeks further orders as
this Hon’ble Court may deem appropriate to protect the
Fundamental Rights of the citizens of India from exploitative
and unethical advertising practices.

2. The present Writ Petition is being filed by the Petitioner, who

is a law student currently pursuing their studies and is deeply
interested in constitutional law and public rights. The petitioner is
committed to understanding the law and ensuring its fair
application to safeguard the interests of the citizens of India.
 It is humbly submitted that the petitioner considers it a moral
duty to bring to the attention of this Hon’ble Court the arbitrary
and unconstitutional practice of using AI technologies in
behavioral advertising to manipulate consumer decisions
through intrusive methods and exploitative use of personal data.
These practices demand urgent judicial scrutiny to uphold the
constitutional rights to privacy, equality, and autonomy.

1. FACTS OF THE CASE

1.1 Artificial Intelligence (AI) refers to the simulation of human

intelligence processes by machines, particularly computer
systems. These processes include learning (acquiring data and
rules for its use), reasoning (using rules to reach conclusions),
and self-correction. Within advertising, AI technologies
analyze user behavior, preference and interactions to predict
and influence consumer decisions.

1.2 Behavioral advertising is a marketing strategy where AI

systems track users’ online activities to create personalized
advertisements. By analyzing data such as browsing history,
search queries, and social media interactions, advertisers target
consumers with tailored messages designed to evoke emotional
responses and influence purchasing decisions.

1.3AI-driven advertising leverages various advanced techniques,

including: monitoring techniques that either measure blood flow
or electric activities in brain (FMRI) Functional Magnetic
Resonance Imaging uses magnetic fields and radio waves to
produce high quality two or three dimensional images of brain
 structures without injecting radioactive tracers. Functional MRI
(FMRI) measures brain activity under restricting and activated
conditions. It can produce images of brain activity as fast as
every second and enables scientists to make “movies” of
changes in brain activity as patients/test subjects perform
different tests or are exposed to various stimuli.

1.4 (QEEG) Quantitative Electroencephalography is the

measurement of electrical patterns at the surface of the scalp
which reflect cortical activity, and are commonly referred as
brainwaves. QEEG is the analysis of the digitized QEEG
A.K.A Brain Mapping. QEEG procedure that processes the
recorded EEG activity from a multi-electrode recording using a
computer. The multi-channel EEG data is processed with
various algorithms, such as “Fourier” classically, or in more
modern applications. The digital data is statistically analysed,
sometimes comparing values with normative database
reference values.

1.5(SST) Steady-State Topography is a methodology for observing

and measuring human brain activity. The SST methodology has
been used to examine normal brain function associated with
visual vigilance, working memory, long-term memory,
emotional processes, as well as disturbed brain functions such
as Schizophrenia and attention deficit Hyperactivity disorder.

1.6 Techniques that indicate Psychological or Physiological arousal

and changes in emotional responses of test subjects. Eye-
Tracking: Is a tool for the analysis of visual attention, it seeks
to associate visual attention with the cognitive and emotional
 responses. This makes the measurement process more subtle,
with very little or no interaction between the researchers and
their subjects. Eye-Tracking measures where the person is
looking (named Gaze or fixation point), the time that this
person looked at this certain point, the movement of his eyes
(and moreover, the sequence in which the eyes shift from one
spot to another), pupil dilation, and the number of blinks.
Understanding the mechanisms that guide consumers to select
certain points of interest in an image having many applications
from the business world.

1.7 (GSR) Galvanic Skin Response which falls under the umbrella
term of Electrodermal Activity or EDA, refers to changes in
sweat gland activity that are reflective of the intensity of
emotional state, otherwise known as emotional arousal changes
in response to the environment we are in – if something is
scary, threatening, joyful or otherwise emotionally relevant,
then the subsequent change in emotional response that we
experience also increases Eccrine sweat gland activity. It is
noteworthy that both positive and negative stimuli can result in
an increase in arousal and in an increase in skin conductance.
The GSR signal representative of the intensity of emotion.

1.8 (FC) Facial Coding: The method of facial coding relies on the
technical advancements to detect facial expressions that reveal
our emotions. Technically it is based on a combination of
Image Recognition, Machine Learning and Deep Learning
Algorithms where the Self-Learning Algorithm for pattern
recognition detects ley facial characteristics such as mouth, eye
and eyebrows. Changes in these features are used to classify
 distinct emotional states. This way small changes in facial
expressions can be detected and interpreted. Facial Coding
automatically generate objective interpretations on emotional
reactions, e.g. towards film sequences or during media
consumption. Facial Coding can be applied to various potential
application areas such as analysis and optimizing of sales calls
and customer service experience, detection of unconscious
emotions during media consumption. Facial Coding can
advance other research methods as EEG and EyeTracking by
allowing objective conclusions about emotional states,
improving visual stimuli and storylines based on emotional
reactions with facial coding we can detect emotional responses
to media and digital content, such as presentations,
communications materials or any other digital; stimuli,
compliment these results with additional neuroscientific
methods, such as EEG, Eye-Tracking, implicit association
testing and GSR measurement, to measure and visualize both
the mental and emotional response of participants

1.9 In light of recent developments in technology, particularly with

AI-driven behavioral advertising, there is an increasing
intrusion on individual privacy rights, especially concerning
biometric data. The Patel v. Facebook, Inc. (2020) judgment
provides a critical precedent regarding the misuse of biometric
data by private companies for commercial purposes, without
informed consent. This case highlights the harmful effects of
facial-recognition technologies, which are used for collecting
and storing biometric data in ways that violate privacy rights
under the Right to Privacy guaranteed by Article 21 of the
Constitution of India.
(a) The case involved the use of biometric data, specifically
facial recognition technology, by Facebook to create face
templates of individuals based on their photographs. This
was done without obtaining explicit consent from users,
raising serious concerns about privacy violations. The
judgment reinforced the substantive privacy rights of
individuals, ruling that the collection and use of biometric
data without informed consent is an intrusion into one's
private affairs, which can lead to significant harm,
particularly in the digital age. The court held that individuals
have a concrete privacy interest in controlling the use of
their biometric data, and violations of the statutory
requirements of data protection laws (like BIPA - Biometric
Information Privacy Act) are actionable.
(b) In this context, the practices employed in AI-driven
advertising that collect, store, and utilize sensitive biometric
and personal data without user consent should be considered
an infringement of fundamental rights. The judgment
underscores the necessity of regulatory oversight and
transparency in how private entities handle personal data,
particularly in the digital advertising sector, where
manipulation through AI technologies is rampant.
(c) This judgment further reinforces the need for stronger
privacy protections, particularly with regard to the use of AI
technologies that have the potential to bypass informed
consent and manipulate consumer behavior. It highlights the
dangers of technologies like AI facial recognition in
advertising, which could be used to track, analyze, and
influence consumer behavior without explicit consent or
knowledge.
1.10Traditional methods of market research typically involve
surveys or questionnaires where participants consciously
decide what information to disclose. This process relies on the
participants' honesty and their ability to recall accurate details.
AI-driven advertising, on the other hand, bypasses this
decision-making process by analyzing users' digital footprints,
such as browsing history and social media interactions, to
predict their preferences and behavior.

1.11 Additionally, these companies have been found to use cookies,

tracking pixels, and other technologies to monitor and influence
user behavior across platforms, often without users’ knowledge
or proper consent management. These actions are in violation
of privacy laws , which have been implemented to safeguard
consumer rights. Attached to this petition are excerpts from
these companies' privacy policies showing their data collection
practices, including the use of cookies, tracking technologies,
and third-party sharing of user data, which expose the
widespread misuse of personal information for commercial
gain, ANNEXURE A. Such practices not only undermine
privacy but also manipulate user behavior, which leads to
significant concerns regarding the autonomy of individuals to
make informed choices. These actions highlight the urgent need
for judicial intervention to regulate the use of such invasive
technologies and to protect the privacy of individuals from
further exploitation
1.12 A commercial practice is deemed unfair if it deviates from
professional diligence standards and significantly distorts, or is
capable of distorting, the economic behavior of targeted
consumers. Professional diligence includes fairness and good
faith principles in consumer dealings. In AI-driven advertising,
the potential to manipulate consumer decisions is heightened,
raising ethical concerns about fairness and the exploitation of
consumer vulnerabilities. AI-driven advertising relies on
processing vast amounts of user data collected through various
platforms. This data reflects consumer behavior, preferences,
and emotional responses. Such data processing meets the
criteria for sensitive personal data under privacy laws.

1.13 In behavioral advertising, data collected from users is

analyzed to derive patterns and insights. These insights are used
to design targeted advertisements that appeal to specific
emotional triggers or biases. For example, advertisements
referencing cultural or emotional themes can activate memory
associations, leading consumers to make biased decisions
favoring certain products. Modern advertising practices
prioritize profit over ethical standards and consumer autonomy,
often crossing constitutional boundaries. This raises significant
concerns about privacy and informed consent under Articles 14,
19, and 21 of the Constitution of India. The petitioner has no
other alternative remedy except to invoke the extraordinary
jurisdiction of this Hon’ble Supreme Court under Article 32 of
the Constitution of India.
 2. GROUNDS

2.1 BECAUSE The unfair practice of AI-driven behavioral

advertising adversely affects the interests of the people of
India, infringing on their fundamental rights without their
informed consent. Urgent intervention of this Hon’ble Court
is necessary to address violations of the basic structure
doctrine as laid down by the Supreme Court. The Preamble
of the Constitution, which guarantees Justice, Liberty, and
Equality, is violated by AI-driven advertising techniques that
exploit consumer vulnerabilities and exclude citizens from
exercising autonomy over their personal data and decisions.

2.2 BECAUSE The concept of personal autonomy is enshrined

in the Fundamental Rights under Part III of the Constitution
of India. Article 19 guarantee.
(a) Freedom of speech and expression, and
(b) Freedom to move freely throughout the territory of
India.

AI-driven advertising infringes on these rights by using

personalized content designed to manipulate consumer
behavior, often without their explicit consent, thereby
compromising their ability to act autonomously and freely
express themselves.

2.3 BECAUSE Article 21 ensures that no person shall be

deprived of life or personal liberty except according to a
procedure established by law. AI-driven advertising
undermines this principle by collecting and analyzing
 personal data, including biometric and behavioral
information, without adequate safeguards or informed
consent. The practice raises critical questions about how
private law protects the autonomy of will, particularly in
contexts where consumers are subjected to manipulative
advertising designed to bypass conscious decision-making.

2.4 BECAUSE AI-driven advertising techniques exploit basic

human instincts and emotions rather than engaging with
consumers on a rational and intellectual level. While
personal autonomy includes the right to act freely, it also
entails the duty to act diligently. The manipulative nature of
these techniques significantly limits consumer autonomy and
violates the principles of fairness and good faith that are
fundamental to professional diligence in commercial
practices.

2.5 BECAUSE There is currently no central agency or unified

legislation in India to regulate AI-driven advertising
comprehensively. The Advertising Standards Council of
India (ASCI), a non-statutory body, lacks the authority to
enforce robust protections against such practices. In the
absence of integrated legislation, AI-driven advertising
continues to exploit consumers without accountability,
necessitating judicial intervention to establish a legal
framework that safeguards fundamental rights and ensures
compliance with existing laws.

3. GROUNDS FOR INTERIM RELIEF

 3.1 BECAUSE The ongoing practice of AI-driven behavioral
advertising involves the intrusive collection and use of
personal data, resulting in an immediate violation of
individuals’ fundamental rights to privacy under Article 21 of
the Constitution. Interim relief in the form of an injunction is
required to mitigate these violations until this Hon’ble Court
adjudicates the matter fully.

3.2 BECAUSE The lack of regulation allows advertisers to

continue exploiting vulnerabilities in consumer behavior,
leading to irreparable harm. An interim measure to halt the
implementation of manipulative AI-driven advertising
practices is essential to prevent further erosion of consumer
autonomy and maintain the status quo.

3.3 BECAUSE The absence of any centralized authority or

robust legal framework to oversee AI-driven advertising
practices exacerbates the potential for abuse. Interim relief
will ensure that no further harm is inflicted on consumers
while this Hon’ble Court considers the broader constitutional
and legislative implications of the case.
 MAIN PRAYER

In light of the aforesaid, the petitioner, therefore, prays that this

Hon’ble Court may kindly be pleased to:

a. Issue a writ of Mandamus or any other appropriate writ, order,

or direction declaring AI-driven behavioral advertising as
unethical, unlawful, and unconstitutional in nature, violating
Articles 14, 19, and 21 of the Constitution of India.

b. Direct the legislature to form a Central/Unified Integrated

Regulatory Legislation to monitor advertisements across all
multimedia platforms, regulating AI-based advertising practices
to protect consumers’ rights and privacy.

c. Recognize that AI-driven behavioral advertising violates the

fundamental rights of privacy and autonomy under Articles 19
and 21 of the Constitution. The Court should express preference
for the protection of individual autonomy and privacy over the
economic interests of business entities using such advertising
techniques.

d. Declare that the absence of informed consent in the collection

and use of personal data for targeted advertising infringes upon
constitutional rights, and direct the establishment of mechanisms
to ensure transparency, fairness, and informed consent in the
processing and use of personal data under Article 21.
 e. Set up clear borders and guidelines to distinguish permissible
advertising practices from prohibited manipulative techniques
that exploit human instincts and emotions, providing clarity for
both consumers and businesses, in line with Article 14 (Right to
Equality).

f. Formulate specific legal safeguards to protect against misuse of

personal data, including sensitive biometric data, in advertising
practices under Section 43A of the Information Technology Act,
2000, and Article 21 of the Constitution, to prevent further
erosion of individual rights.

g. Recognize the Right to Privacy as inclusive of mental and

emotional space under Article 21, and declare the autonomy of
will as an extension of personal freedom under Article 19 (Right
to Freedom).

INTERIM PRAYER

Pending final adjudication of the present writ petition, the

petitioner prays that this Hon’ble Court may kindly be pleased
to:

a. Issue an interim injunction restraining advertising entities

from employing AI-driven behavioral advertising
techniques that involve the collection, processing, or
utilization of personal and biometric data without explicit
and informed consent, in violation of Articles 19 and 21.
 b. Direct the Union of India to create temporary guidelines
or a framework for oversight of AI-based advertising
practices to prevent further harm to individual privacy and
autonomy during the pendency of this petition, in
compliance with Section 43A of the Information
Technology Act, 2000, and Article 21 of the Constitution.

c. Suspend the deployment of AI-driven advertisements

across all platforms until proper regulations are
formulated to address the constitutional and legal concerns
raised herein, ensuring compliance with Article 14 (Right
to Equality) and Article 21 (Right to Privacy).

d. Establish an interim oversight committee comprising

legal, technical, and consumer rights experts to monitor
and review AI-driven advertising practices, ensuring
compliance with ethical and legal standards during the
pendency of this writ petition.

e. Provide any further interim relief that this Hon’ble Court

deems fit and necessary to protect the fundamental rights
of citizens during the pendency of this writ petition under
Article 32 of the Constitution

AND FOR THIS ACT OF KINDNESS THE PETITIONER AS

IN DUTY BOUND SHALL EVER PRAY
Date: December, 5, 2024
Place: Bengaluru, Tavarekere
DRAWN BY :
SOUNDARYA D N
 ( Petitioner Itself)

IN THE SUPREME COURT OF INDIA

EXTRA ORDINARY ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. ________ OF 2022
(P.I.L) PUBLIC INTEREST LITIGATION
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF:

SOUNDARYA D N …
PETITIONER
Versus
UNION OF INDIA …RESPONDENT

AFFIDAVIT
I, Soundarya D N , D/o. Nagaraju D A, aged 2O years, R/o M401,
Sispal Vihar (AWHO), Sector 49, Sohna Road, Bengaluru
Karnataka , 562130 do hereby solemnly affirm and state on oath
as follows:
1. I am the petitioner in the above matter and I am
fully conversant with the facts and circumstances of
the case and competent to swear the present affidavit.
2. I have read and understood the contents of the
accompanying writ petition Synopsis and List of
Dates from Page No. 1 to 7 and also the
accompanying writ petition in Public Interest (page
 No. 8 to 19) which have been drafted by me and I say
that the contents of the same are true and correct.
3. I say that the contents of the petition are based
through the knowledge derived by various research
papers, Books, Investigation Documentaries, Legal
cases, previous judgements and News reports.
4. I say that the Annexure A annexed with the petition
is true and copy of its original.
Soundarya
DEPONENT

VERIFICATION:
Verified at New Delhi on this 5th day of December , 2024 , that the
facts stated herein are true to the best of my knowledge and belief,
no part of it is false and nothing material has been concealed
therefrom.
Soundarya
DEPONENT
 APPENDIX

Article 32 in The Constitution Of India 1949

32. Remedies for enforcement of rights conferred by this Part

(1) The right to move the Supreme Court by appropriate proceedings

for the enforcement of the rights conferred by this Part is
guaranteed

(2) The Supreme Court shall have power to issue directions or orders
or writs, including writs in the nature of habeas corpus,
mandamus, prohibition, quo warranto and certiorari, whichever
may be appropriate, for the enforcement of any of the rights
conferred by this Part

(3) Without prejudice to the powers conferred on the Supreme Court

by clause ( 1 ) and ( 2 ), Parliament may by law empower any
other court to exercise within the local limits of its jurisdiction all
or any of the powers exercisable by the Supreme Court under
clause ( 2 )

(4) The right guaranteed by this article shall not be suspended

except as otherwise provided for by this Constitution
 IN THE SUPREME COURT OF INDIA
EXTRA ORDINARY ORIGINAL JURISDICTION
WRIT PETITION (CIVIL) NO. ________ OF 2024
(P.I.L) PUBLIC INTEREST LITIGATION
(UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA)

IN THE MATTER OF:

SOUNDARYA D N ...PETITIONERS

Versus
UNION OF INDIA ...RESPONDENT

WRIT PETITION UNDER ARTICLE 32 OF

THECONSTITUTION OF INDIA SEEKING A WRIT OR
ORDER OR DIRECTION IN THE NATURE OF
MANDAMUS DECLARING AI-DRIVEN BEHAVIORAL
ADVERTISING AS ILLEGAL, UNCONSTITUTIONAL
FOR BEING VIOLATIVE OF ARTICLE 14, ARTICLE 19 &
ARTICLE 21 (RIGHT TO PRIVACY) OF THE
CONSTITUTION OF INDIA, AND PASS SUCH FURTHER
ORDER AS THIS HON’BLE COURT MAY DEEM
APPROPRIATE TO PROTECT THE FUNDAMENTAL
RIGHTS OF THE CITIZENS OF INDIA.
PETITIONER ITSELF: SOUNDARYA D N
To,
The Hon'ble Chief Justice of India
& His Companion Judges of this Hon'ble Court

The Writ Petition of the Petitioner

MOST RESPECTFULLY SHOWETH:

1. That the above-mentioned Writ Petition is being filed by the
petitioner under Article 32 of the Constitution of India, praying
for the issuance of a writ of mandamus or appropriate directions
from this Hon’ble Court to regulate AI-driven behavioral
advertising practices that infringe upon individuals’ privacy
rights under Article 21, Article 19, and Article 14 of the
Constitution. The petitioner seeks judicial intervention to
establish safeguards against manipulative advertising techniques
that exploit personal and biometric data without informed
consent, violating the fundamental rights of citizens.
2. The petitioner has, for the sake of brevity, refrained from
repeating the averments made in the accompanying petition,
which comprehensively details the material facts and relies upon
legal principles to substantiate the claim. The averments made in
the accompanying petition may kindly be read as an integral part
of this application.
3. That the petitioner, as a law student, is filing this Writ Petition in
public interest, motivated by a strong sense of responsibility to
protect the constitutional rights of individuals. The petitioner is
well-versed in the principles of constitutional law and consumer
protection and respectfully requests to appear and argue in
person before this Hon’ble Court.
PRAYER
In the above circumstances it is therefore most respectfully prayed
that this Hon’ble Court may pleased to :
(a) to the petitioner to appear and argue in person in this petition;
(b) Pass such other order or orders as this Hon’ble would deem
fit and proper in the facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS THE PETITIONERS AS
DUTY BOUND SHALL EVER PRAY.

Filed By:
Soundarya D N
Petitioner – In Person
Mobile -8073215528
E-mail- soundaryadn6@[Link].
ANNEXURE - A

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