The passage of the Digital Personal Data Protection Act (DPDP) by the Indian Parliament in 2023, and its full implementation in November of this year, has sent a shiver of apprehension through the hearts of civil society and minority rights advocates across the nation. While ostensibly designed to safeguard personal privacy, this new legislation, they fear, is being wielded as a formidable weapon that will severely impede their crucial work, particularly the monitoring and documentation of rising Christian persecution. This development arrives at a profoundly sensitive moment for the country, where the fundamental freedoms of speech and expression are already under increasing strain from the federal government, led by the pro-Hindu Bharatiya Janata Party (BJP) and its powerful ideological parent, the Rashtriya Swayamsevak Sangh (RSS).

The Erosion of the Right to Information

One of the most immediate and alarming consequences of the DPDP Act is the manner in which it effectively neuters the landmark Right to Information Act (RTI) of 2005. The RTI, a beacon of transparency passed by the previous Congress-led coalition, was a vital tool for citizens seeking to hold power accountable. The government of Prime Minister Narendra Modi has now fundamentally altered the RTI by removing its core safeguard: Section 8(1)(j). This section previously allowed for the disclosure of a public servant’s personal information if it served the larger public interest, such as exposing corruption or human rights abuses.

The amendment replaces this public-interest exception with a starkly simple rule: “Information which relates to personal information” shall not be disclosed. This change is not merely bureaucratic; it carries grave implications for transparency and accountability, especially for India’s 28 million Christians and other religious minorities who have long relied on the RTI to document persecution and official malfeasance.

A Shield for the Complicit

The public-interest clause was the very lifeblood of advocacy. It allowed activists to obtain critical details: the names of police officers who refused to register First Information Reports (FIRs) following attacks on churches, records of their communication with vigilante groups, lists of beneficiaries excluded from government schemes—especially Dalit Christians—and status updates on investigations into hate crimes.

This is precisely the kind of information Christian groups require to pursue public interest litigations in state high courts and the Supreme Court of India. Such evidence is essential to substantiate allegations of persecution and the denial of rights to people who converted from Hindu castes once deemed “untouchable,” who still face profound exclusion in society, particularly in rural India.

With the public-interest exception summarily removed by the digital law amendment, any information classified as personal is now exempt from RTI disclosure, regardless of its importance for public accountability or human rights. Legal experts, minority rights groups, and former federal information officials have collectively decried this as the biggest setback to the RTI Act since its inception in 2005 4. While the government maintains that the RTI still permits disclosure when public interest outweighs harm, the new wording in the DPDP Act effectively takes precedence, leading public authorities to routinely reject requests, causing a sharp increase in appeals.

The Rising Tide of Persecution

This legislative setback comes as the Christian community, alongside Muslims, faces a demonstrable rise in hostility. Independent monitoring groups have recorded a disturbing surge in incidents of violence and intimidation.

Monitoring Group	Incidents Recorded (2024)	Incidents Recorded (Jan-Oct 2025)
United Christian Forum (UCF)	731	672
Evangelical Fellowship of India (EFI)	N/A	334 (Jan-Jul 2025) 5
Persecution Relief	640	Projected over 800

The UCF, for instance, recorded 834 verified acts of violence and intimidation against Christians in 2024, a figure that highlights the severity of the situation 6. The Evangelical Fellowship of India’s Religious Liberty Commission (EFIRLC) documented 334 incidents of systematic targeting between January and July 2025 alone, with the rate of violence now averaging two incidents per day.

These figures are not mere conjecture; they are built upon a foundation of field visits, victim testimonies, FIR copies, court documents, and, critically, RTI replies. The new digital law now threatens to block or even criminalize several of these essential sources of evidence. It is important to note that the Catholic Church and the National Council of Churches in India, which comprises Protestant denominations, do not independently monitor persecution but rely on the data compiled by these dedicated monitoring groups.

International Alarm

The situation has caused widespread consternation in international circles. The Open Doors World Watch List ranked India 11th this year, noting a level of extreme persecution in at least 26 states 8. Furthermore, the US Commission on International Religious Freedom (USCIRF) has repeatedly recommended that India remain designated as a “country of particular concern” for the sixth consecutive year 9. The Indian government, however, routinely dismisses such international data, characterizing it as unwarranted interference in the internal affairs of a democratic nation.

The Threat to Journalists and Activists

Equally, if not more, dangerous is the threat the new digital law poses to activists and journalists, who are now deemed to be “data fiduciaries.”

In effect, anyone who systematically collects personal data—names, photographs, national identity numbers, phone records, or testimonies—for the purpose of reporting or advocacy now falls under the purview of the law. To comply, they must secure clear consent from every person whose data they collect, limit the scope of data collection, and also allow individuals to withdraw consent or request deletion. Failure to adhere to these stringent requirements can invite hefty fines.

This presents an existential crisis for those documenting persecution. Victims often fear providing written consent, as it could expose them to reprisals from perpetrators or complicit officials, who themselves will never consent to the release of their own data. While anonymized data can be collected, it is insufficient to prove patterns of bias or to establish repeat offenses by named perpetrators.

The law, therefore, provides a new mechanism for perpetrators or officials supporting them to harass activists and monitoring groups. Several non-governmental organizations have already received notices under the new law, even before its final rules were fully established.

Lack of Journalistic Exemption

A key point of contention is the law’s failure to include a clear exemption for journalistic purposes. Unlike the European Union’s General Data Protection Regulation (GDPR) and the UK’s Data Protection Act 2018, which contain explicit exemptions for journalism, academic, artistic, or literary expression when done in the public interest, the Indian law offers no such safeguard.

The Editors Guild of India and the Digital News Publishers Association have stated that the lack of clear journalistic exemptions makes reporting on communal violence legally perilous. Consequently, many mainstream media outlets have already begun to self-censor, avoiding the naming of perpetrators or police officers in their reports on minority attacks, citing legal concerns.

The Case of Dalit Christians and Manipur

For Dalit Christians, the RTI Act was the primary tool used to prove ongoing discrimination against them, but this route is now largely closed.

In tribal-dominated states such as Chhattisgarh, Jharkhand, Odisha, and Manipur, attacks on Christians have intensified. RTI replies previously provided evidence of police inaction or even the supplying of arms to village defense committees. Now, similar queries are being rejected.

Furthermore, anti-conversion laws in 12 Indian states require permission for religious conversions and place the burden of proof on the accused. The RTI was previously used to demonstrate that 90-95 percent of cases filed under these laws ultimately end in acquittal or closure in courts, thereby proving their widespread misuse. Such vital statistics are now becoming increasingly difficult to obtain.

The devastating ethnic violence in Manipur since May 2023, which resulted in the damage or destruction of over 5,000 churches and the displacement of more than 60,000 Kuki-Zo Christians, serves as a stark example. RTI replies had previously confirmed that police arms reached militias. Now, similar attempts to seek accountability through information are being thwarted by the new data protection regime.

The DPDP Act, in its current form, represents a profound challenge to the Church’s mission of justice and truth in India. By obscuring the mechanisms of persecution and silencing the voices of those who document it, the law risks creating a veil of digital darkness behind which human rights abuses can proliferate unchecked.