A Comparative Study of Right to Privacy As a Human Right with Special Reference to India, United Kingdom and USA

The research is undertaken on the concept of privacy as a right that safeguards
the personal or intimate facets of an individual and a comparative analysis of Right to
Privacy in India, USA and UK. The outlook of the study is a critical analysis on the
concept of privacy as a fundamental right and yet not having a separate identity
neither through a legislative enactment nor as an exclusive part of the Constitution.
This situation being common to India and most of the developed nations including
USA and UK. The reason for the lack of boost to this concept could be the
inefficiency of the parliamentarians including the lack of importance accorded to it by
the general public.
Even though in the modern-day advancement in technology has been more
intrusive into the personal space of the individuals that ever, privacy is only
highlighted through judicial decisions and no attempt has been made to provide for a
comprehensive legislation pertaining to the Right to Privacy. In India, no doubt the
Privacy Bill 2014 has been passed, yet the Bill mostly deals with matters relating to
Data Privacy even though there are many areas where privacy needs to be protected.
Similar are the positions in USA and UK. However, in USA and UK the concept is
much developed as compared to India.
Privacy as an idea may seem very limited and narrow, but when it comes to
practicality the concept is much wider and calls for extensive research as to the extent
it could be granted to the individuals. Like any other fundamental rights enshrined in
the Indian Constitution, Privacy also needs to be reasonably restricted. Striking a
balance between the interest of the people and the State concerns is a herculean task
that can only be brought through extensive analysis of the idea of privacy, preferably
on a case-to-case basis. This could only be possible when Privacy is taken as an
exclusive part of academic study.