International Journal of Trend in Scientific Research and Development (IJTSRD)

Volume: 3 | Issue: 4 | May-Jun 2019 Available Online: www.ijtsrd.com e-ISSN: 2456 - 6470

Cyber Crime Scenario in India and Judicial Response

Nidhi Arya
LLM, Chandigarh University, Mohali, Punjab, India

How to cite this paper: Nidhi Arya ABSTRACT

"Cyber Crime Scenario in India and The internet in India is growing rapidly. It has given rise to new opportunity in
Judicial Response" Published in every field like – entertainment, business, sports, education etc. It is universally
International Journal of Trend in true that every coin has two sides, same for the internet, it uses has both
Scientific Research and Development advantage and disadvantage, and one of the most disadvantage is Cyber-crime.1
(ijtsrd), ISSN: 2456-
6470, Volume-3 | Cyber crime is emerging as a serious threat. Worldwide governments, police
Issue-4, June 2019, departments and intelligence units have started to react2. Initiatives to curb
pp.1108-1112, URL: cross border cyber threats are taking shape. Indian police has initiated special
https://www.ijtsrd.c cyber cells across the country and have started educating the personnel. This
om/papers/ijtsrd24 article is an attempt to provide a glimpse on cyber crime in India. This article is
025.pdf IJTSRD24025 based on various reports from news media and news portal.

Copyright © 2019 by author(s) and

International Journal of Trend in Keywords: Cyber crime, Internet, Hacking, Phishing, Cyber squatting
Scientific Research and Development
Journal. This is an Open Access article 1. INTRODUCTION
distributed under The world of Internet today has become a parallel form of life and living. Public
the terms of the are now capable of doing things which were not imaginable few years ago. The
Creative Commons Internet is fast becoming a way of life for millions of people and also a way of
Attribution License (CC BY 4.0) living because of growing dependence and reliance of the mankind on these
(http://creativecommons.org/licenses/ machines.
by/4.0)
Internet has enabled the use of website communication, through cause of action; it is a combination of computer and
email and a lot of anytime anywhere IT solutions for the crime.3
betterment of human kind.1
In Asia region India has rank top two internet users country,
In present generation its rapid growth on Information so India is the very fastest growing country. Today internet
Technology is enclosing all walks of life. These technical becomes the backbone of social & economic world. Users can
improvements have made the transformation from access the internet anytime from anywhere but through the
document to paperless communication possible. Whereas internet many illegal works may done. Today E-mail and
computer are meant to store privileged data of Political, website is the most efficient way of data communication.4
social, economic which brings huge benefits to the society.
The wide extension of an internet and Computer technology 2. CYBERSPACE:
globally has led to escalation of internet related crimes.2 The term “cyberspace “ was first used by the cyberpunk
science fiction author William Gibson, which he later
In recent times, India has become major spot for cyber described as an “evocative and essentially meaningless
criminals, who most hackers and other malicious users “buzzword” that could serve as a cipher for all of his
commit crimes through internet. As there as various types of cybernetic musings. Now it is used to describe anything
cyber crimes these crimes are rising at a terrifying rate. India associated with computers, information technology, the
is ranked fifth in cyber crime amongst other countries. Under internet and the diverse internet culture. Cyberspace is the
Indian law cyber crime does not have any specific definition electronic medium of computer networks, in which online
under any Indian legislation one legislation that deals with communication taken place and where individuals can
offences related to such crime is Information technology Act, interact, exchange ideas ,share information, provide social
2000 which was later amended as Information Technology support, conduct business, direct actions, create artistic
Act, 2008. In order to define such an offence, it can be done media, play games, engage in political discussion, and so on.
It is readily identified with the interconnected information
1 Justice Yatindra Singh, Cyber Laws 36 (universal law technology required to achieve the wide range of system
publishing, Delhi, 6th edn.,1998)
1 Dr. Jyoti Rattan and Dr. Vijay Rattan , Cyber Laws &

Information Technology 47 (Bharat law publishing,

Calcutta,6th edn.,2017)
1 Dr. Faruq Ahmed, Cyber Law in India 67 (New Era Law 3 B. Swaathi and M. Kannappan, “Cyber Crime-An Indian
Publication, Ahmedabad, 3rd edn., 2002) Scenario”119 ISSN 1053 (2018)
2 Ibid. 4 Ibid.

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 International Journal of Trend in Scientific Research and Development (IJTSRD) @ www.ijtsrd.com eISSN: 2456-6470
capabilities associated with the transport of communication to include traditional crimes in which computers or
and control product and services.5 networks are used to enable the illicit activity.11

Cyberspace is the “place “where a telephone conversation 4. DEFINITION OF CYBER CRIME:

appears to occur. Not inside your actual phone, the plastic The Indian Legislature doesn’t provide the exact definition of
device on your desk. Not inside the other person’s phone, in Cyber crime in any statute, even the Information Technology
some other city. the place between the phones in the past Act, 2000; which deals with cyber crime doesn’t defined the
twenty years, this electrical “space”, which was once thin and term of cyber crime. However in general the term
dark and one dimensional –little more than a narrow cybercrime means any illegal activity which is carried over
speaking –tube, stretching from phone to phone has flung or with the help of internet or computers.
itself open like a gigantic jack-in-the-box.6 Light has flooded
upon it, the eerie light of the glowing computer screen. This In the words of Dr. Debarati Halder and Dr. K. Jaishankar,
dark eclectic netherworld has become a vast flowering, cybercrimes are “Offences that are committed against
electronic landscape. Since the 1960s, the words of the individuals or groups of individuals with a criminal motive to
telephone has cross-bred itself with computers and intentionally harm the reputation of the victim or cause
television, and though there is still no substance to physical or mental harm, or loss, to the victim directly or
cyberspace, nothing you can handle, it has a strange kind of indirectly, using modern telecommunication networks such
physicality now. It makes good sense today to talk of as Internet (Chat rooms, emails, notice boards and groups)
cyberspace as a place all its own.7 and mobile phones (SMS/MMS).”12

Electricity was first harnessed in 1831, but it was not until In the words of Pawan Duggal, “Cyber crime refers to all the
1882 that the first power station was built in 1882. Then it activities done with criminal intent in cyberspace or using
took another 50 years before reaching 80 percent in United the medium of internet. These could be either the criminal
States. Radio took 38 years to be used by 50 million people. activities in the conventional sense or activities, newly
TV took 13 years to reach 50 million people, whereas PC evolved with the growth of the new medium. Any activity,
took 16 years to reach 50 million people. However, the which basically offends human sensibilities, can be included
internet took only 4 years to have 50 million people online; in the ambit of cybercrimes.”
thus, increasing the horizon of cyber space.8
In the words of Dr. R.K. Tewari, “cyber crime may be said
3. WHAT IS CYBER CRIME? those species, of which, genus in the conventional crime, and
“Cybercrime” is a combination of two terms “crime” with the where either the computer is an object or subject of the
root “cyber” derived from the word “cybernetic”, from the conduct constituting crime”.13
Greek, “kubernan”, which means to lead or govern. The
“cyber” environment includes all forms of digital activities, According to UNO expert recommendations, the term of
irrespective of whether they utilize single network. “cybercrimes “covers any crime committed by using
Cyberspace is borderless as no Courts across the globe can computer system or networks, within their framework or
claim jurisdiction. Any illegal act which involves a computer, against them. Theoretically, it embraces any crime that can
computer system or a computer network is cybercrime.9 be committed in the electronic environment. In other words,
crimes committed by using e-computers against information
Crime consists of engaging in conduct that has been processed and applied in the internet can be referred to
outlawed by a society because it threatens the society’s cybercrimes.14
ability to maintain order.
In the words of Katyal, “cyber crimes are offences conducted
The expression crime is defined as an act which subjects the in the “cyberspace” and the term “cyberspace” is ambiguous
doer to legal punishment or any offence against morality, in the first place. A diverse range of act such as the spread of
social order or any unjust or shameful act. The offence is computer viruses, visting an obscene website and cyber
defined in code of criminal code of criminal procedure to stalking may qualify as a cybercrime”.15
make punishable by any law for the time being in force.10
5. OBJECTIVES:
Cyber crime is a term used to broadly describe criminal
To Study the implementation on enactments of cyber
activity in which computer networks are a tool, a target, or a law.
place of criminal activity and include everything from
To know the types cyber crimes and its functions.
electronic cracking to denial of service attacks. It is also used

5 Dr. Jyoti Ratan, Cyber laws & information technology 54 11 IBID

(universal publication, new Delhi, 4th edn., 2014). 12 Jonathan clough, Principles of Cybercrime 12( cambridge
6 Dr. Amita Verma , Cyber Crimes & Law 47( universal publication , 2ndedn 1998)
publication, new Delhi 1stedn., 2009) 13 Petter Gottschalk ,Policing Cyber Crime 75 ( Lexix Nexix
7 Sudershan ,Goel Ravi Sodhi, crime law & advice 67 ( kamal Publication , 2ndedn 2002)
public house publication, Ahmadabad, 2ndedn., 2012) . 14 Deccan Chronicle , Cybercrime, available at:
8 IBID https://www.deccanchronicle.com/nation/crime/200718/i
9 Rohasnagpal , Cyber Crime and Corporate Liability 45 ( ndias-cybercrime-scenario-ground-situation-alarming.html (
4thedn 1997) last visited on 25th October 2018)
10 Animesh Sarmah, Roshmi Sarmah ,Amlan Jyoti Baruah, “ A 15 Om Bhusan , “ CYBER CRIME-Definition, challenges and

brief study on Cyber Crime and Cyber Law’s of India Volume: the cost, ISSN 2347 – 8527 Volume 3, Issue 2 April 2014” (
04 Issue: 06 June 2017 ( last visited on 25th October 2018) last visited on 23rd October 2018)

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To analyze the problems faced by the police for viewed by other users. Examples of such code include HTML
investigation on cybercriminals.16 code and client-side scripts. An exploited cross-site scripting
vulnerability can be used by attackers to bypass access
5. CYBER CRIME INCLUDES: controls21.
Following are the few examples of cyber Crime:
5.1.1. Email spoofing: 5.1.7. Vishing:
This technique is a forgery of an email header. This means Vishing is the criminal practice of using social engineering
that the message appears to have received from someone or and Voice over IP (VoIP) to gain access to private .personal
somewhere other than the genuine or actual source. These and financial information from the public for the purpose of
tactics are usually used in spam campaigns or in phishing, financial reward. The term is a combination of "voice" and
because people are probably going to open an electronic phishing. Vishing exploits the public's trust in landline
mail or an email when they think that the email has been telephone services, which have traditionally terminated in
sent by a legitimate source.17 physical locations which are known to the telephone
company, and associated with a bill-payer. The victim is
5.1.2. Hacking: often unaware that VoIP allows for caller ID spoofing,
Amongst all types of cyber crime it is the most dangerous inexpensive, complex automated systems and anonymity for
and serious threat to the internet and e-commerce. Hacking the billpayer. Vishing is typically used to steal credit card
refers to the secretively breaking into the computer system numbers or other information used in identity theft schemes
and stealing valuable data from the system without any from individuals.22
permission. Spreading computer virus: It refers a set of
Cyber instructions which are able to perform some malicious 5.1.8. Cyber trafficking:
operations. Viruses stop the normal functioning of the It may be trafficking in weapons, drugs, human beings, which
system programs and insert few abnormalities. A computer affect the large numbers of persons.
viruses can be spread through- Emails, CDs, pen drives
(secondary storage), Multimedia, Internet.18 5.1.9. Web jacking:
The term Web jacking has been derived from hi jacking. In
5.1.3. Phishing: this offence the attacker creates a fake website and when the
Phishing refers to stealing information’s like passwords, victim opens the link a new page appears with the message
credit card details, usernames etc of target person/persons and they need to click another link. If the victim clicks the
over the internet. Phishing is carried out by email spoofing link that looks real he will redirected to a fake page. These
and instant messaging. In this type of crime hackers make a types of attacks are done to get entrance or to get access and
direct link which directs the targeted persons to the fake controls the site of another. The attacker may also change
page which looks and feels identical to the actual one.19 the information of the victim’s webpage.23

5.1.4. Cyber stalking: 5.1.10. Malicious Software:

Cyber stalking is use of the Internet or other electronic These are Internet-based software or programs that are used
means to stalk someone. This term is used interchangeably to disrupt a network. The software is used to gain access to a
with online harassment and online abuse. Stalking generally system to steal sensitive information or data or causing
involves harassing or threatening behavior that an individual damage to software present in the system.
engages in repeatedly, such as following a person, appearing
at a person's home or place of business, making harassing 5.1.11. SMS Spoofing:
phone calls, leaving written messages or objects, or SMS Spoofing allows changing the name or number text
vandalizing a person's property. messages appear to come from.24

5.1.5. Cyber defamation: 6. ROLE OF JUDICIARY IN EXPANDING CYBER CRIME

Cyber defamation means the harm that is brought on the JURISPRUDENCE:
reputation of an individual in the eyes of other individual A. The Bank NSP Case:
through the cyber space. The purpose of making defamatory In this case a management trainee of a bank got engaged to a
statement is to bring down the reputation of the individual.20 marriage. The couple used to exchange many emails using
the company’s computers. After some time they had broken
5.1.6. Cross site scripting:
Cross-site scripting (XSS) is a type of computer security 21Hemraj Saini, Yerra Shankar Rao, T. C. Panda, “Cyber-
vulnerability typically found in web applications which allow
Crimes and their Impacts: A Review” IJERA, Vol. 2, Issue
code injection by malicious web users into the web pages
2,Mar-Apr 2012, pp.202-209, ( last visited 23rd October
2018)
16 R. P. Kataria & S. K. P. Sriniwas, Cyber Crimes 22 (Orient
Publishing Company, New Delhi 1stedn 2016)
17 Classification of cyber law, available 22 Raghav Punj ,Cybercrime ,available at:
at:https://www.scribd.com/doc/316141735/Characteristic https://www.interpol.int/Crime-
s-of-Cyber-Crime ( last visited on 2ndnov. 2018) areas/Cybercrime/Cybercrime ( last visited on 18th October
2018)
18 Ibid. 23 Ibid.
19 Cyber Crime mans safety , available at: 1) 24 Computer Crime, available at:
http://www.sbsnagarpolice.com/Cyber_crime.htm ( last https://www.lectlaw.com/mjl/cl025.htm (last visited
visited on 12 October 2018) on 22nd October 2018)
20 Ibid.

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up their marriage and the young lady created some fake woman, and forwarded emails received in that account. The
email ids such as “Indian bar associations” and sent mails to victim also received phone calls by people who believed that
the boy‘s foreign clients. She used the banks computer to do she was soliciting for sex work .The police complaint was
this. The boy‘s company lost a huge number of clients and lodged in February 2004 and within a short span of seven
took the bank to court. The bank was held liable for the months from the filing of the First Information Report, the
emails sent using the bank‘s system.25 Chennai Cyber Crime Cell achieved a conviction. Katti was
punished with two years’ rigorous imprisonment and Rs.
B. Bazee.com case: 500 fine under S. 469 IPC (forgery for the purpose of
In December 2004 the Chief Executive Officer of Bazee.com harming reputation), one year’s simple imprisonment and
was arrested because he was selling a compact disk (CD) Rs. 500 for offence under S. 509 IPC (words, gestures or acts
with offensive material on the website, and even CD was also intended to insult the modesty of a woman) and two years’
conjointly sold-out in the market of Delhi. The Delhi police rigorous imprisonment and Rs. 4000 fine for offence under S.
and therefore the Mumbai Police got into action and later the 67 of IT Act 2000 (punishment for publishing or transmitting
CEO was free on bail.26 obscene material in electronic form).30

C. Parliament Attack Case: F. Fatima Riswana v. State Represented by ACP,

The Bureau of Police Research and Development, Hyderabad Chennai and other,31 both the public prosecutor and
had handled this case. A laptop was recovered from the counsel for the petitioners applied to the court for transfer to
terrorist who attacked the Parliament. The laptop which was another (male) judge, to save the district lady judge from
detained from the two terrorists, who were gunned down on embarrassment of having to view certain CDs that are part of
13th December 2001 when the Parliament was under siege, the evidence. The order for transfer was passed and the
was sent to Computer Forensics Division of BPRD. The justification for this was that the “said trial would be about
laptop contained several proofs that affirmed the two the exploitation of women and their use in sexual escapades
terrorist’s motives, mainly the sticker of the Ministry of by the accused, and the evidence in the case is in the form of
Home that they had created on the laptop and affixed on CDs. and viewing of which would be necessary in the course
their ambassador car to achieve entry into Parliament House of the trial, therefore, for a woman Presiding Officer it would
and the fake ID card that one of the two terrorists was cause embarrassment.”32
carrying with a Government of India emblem and seal. The
emblems (of the 3 lions) were carefully scanned and G. S.M.C. Pneumatics (India) Pvt. Ltd. v. Jogesh Kwatra33
additionally the seal was also craftly created together with a India's first case of cyber defamation case, In this case, the
residential address of Jammu and Kashmir. However careful defendant Jogesh Kwatra being an employ of the plaintiff
detection proved that it was all forged and made on the company started sending derogatory, defamatory, obscene,
laptop.27 vulgar, filthy and abusive emails to his employers as also to
different subsidiaries of the said company all over the world
D. Andhra Pradesh Tax Case: with the aim to defame the company and its Managing
The owner of the plastics firm in Andhra Pradesh was Director Mr. R K Malhotra. The plaintiff filed a suit for
arrested and cash of Rs. 22 was recovered from his house by permanent injunction restraining the defendant from doing
the Vigilance Department. They wanted evidence from him his illegal acts of sending derogatory emails to the plaintiff.
concerning the unaccounted cash. The suspected person On behalf of the plaintiffs it was contended that the emails
submitted 6,000 vouchers to prove the legitimacy of trade, sent by the defendant were distinctly obscene, vulgar,
however when careful scrutiny the vouchers and contents of abusive, intimidating, humiliating and defamatory in
his computers it unconcealed that every one of them were nature.34
made after the raids were conducted. It had been concealed
that the suspect was running 5 businesses beneath the H. Air force Bal Bharti School Case35 was filed in the
presence of 1 company and used fake and computerized Juvenile court, Delhi on the charge of cyber pornography.
vouchers to show sales records and save tax. So the dubious Some jurists say this is the first Indian cyber pornographic
techniques of the businessman from the state were exposed case which was charge sheeted in the juvenile court. The
when officials of the department got hold of computers brief facts in issue were that a student of the Air force Bal
utilized by the suspected person.28 Bharti School, Lodhi Road, New Delhi was arrested by the
Delhi Police in the year 2001 April.
E. State of Tamil Nadu v. Suhas Katti,29 decided by a
Chennai court in 2004. The woman, a divorcee, complained 30 Order passed on 5 November 2004 in CC No. 4680 of 2004
to the police about a man who was sending her obscene,
by the Chief Metropolitan Magistrates Court, Egmore,
defamatory and annoying messages in a Yahoo message
Chennai (India
group, after she turned down his proposal for a marriage. 31 Criminal Appeal 63 of 2005 arising out of SLP (Cri) No.
The accused opened a fake email account in the name of the
1606 of 2004 decided by the Supreme Court on January 11,
2005
25 State by Cyber Crime Police vs. Abubakar Siddique 32 Dr. M. Sanjeeva Rao, “ Pornography Needs Strict
26 Avnish Bajaj vs. State (N.C.T.) Of Delhi 3 Comp LJ 364 Del, Regulations in India” Volume 1 ISSN 211(2016)
116 (2005) DLT 427, 2005 (79) DRJ 576 33 Smc Pneumatics (India) Pvt. Ltd vs Shri Jogesh Kwatra on
27 State vs. Mohammad Afjal Delhi 1, 107 (2003) DLT 385, 12 February, 2014
2003 (71) DRJ 178, 2003 (3) JCC 1669 34 Case List: Cyber Defamation, available at:
28 Andhra Pradesh State Road vs. The Income-Tax https://indiancaselaws.wordpress.com/2014/08/23/case-
Officer 1964 AIR SCR (7) 17. list-cyber-defamation/ last visited: march 7 2019)
29 Decided by the Chief Metropolitan Magistrate, Egmore, on 35 The Air Force bal Bharti, Delhi Cyber Pornography Case

November 5, 2004 2001

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The alleged accused was then a class XII student who created the said section. In fact, a large number of innocent persons
a pornographic website as revenge of being teased by have been booked.41
classmates and teachers. He listed in that website the name
of his 12 school mates ‘girls and teachers in sexually explicit The Court held that the provision of section 66A of the IT Act
manner. He was then suspended by the School Authorities is derogative to the Article 19(1) (a) and as such it is an
though the juvenile court allowed his bail prayer. However, arbitrary provision which breaches the right of citizen to
he was charged under s. 67 of the Information Technology have freedom of speech and expression of their views on
Act 2000, and ss. 292, 293, 294 of the Indian Penal Code and internet. As such the provision concerned is constitutionally
the Indecent Representation of Women Act. The most invalid and as such struck down in its entirety.42
significant steps were taken by the law enforcement
agencies in India. 7. CONCLUSION
It is cleared from the previous studies and records that with
Further, Honble Judge also restrained the defendant from the increment in technology cybercrimes increases. Qualified
publishing, transmitting or causing to be published any people commit crime more so, there is need to know about
information in the actual world as also in cyberspace which principles and computer ethics for their use in proper
is derogatory or defamatory or abusive of the plaintiff.36 manner. Cybercrime and hacking is not going away, if
anything it is getting stronger. By studying past incidents, we
I. Shreya Singhal v. U.O.I37 this is a landmark judgment, can learn from them and use that information to prevent
concerning section 66A of the Information Technology Act, future crime. Cyber law will need to change and evolve as
2000. This Section was not in the Act as originally enacted, quickly as hackers do if it has any hopes of controlling
but came into force by virtue of an Amendment Act of 2009 cybercrime. Law must also find a balance between
with effect from 27.10.2009.38 protecting citizens from crime, and infringing on their rights.
The great thing about the internet is how vast and free it is.
The reason behind the insertion of section 66A Will it be able to remain the same way while becoming
according to the Amendment Bill was: tougher on criminals? Only time will tell. There will always
“A rapid increase in the use of computer and internet has be new and unexpected challenges to stay ahead of cyber
given rise to new forms of crimes like publishing sexually criminals and cyber terrorists but we can win only through
explicit materials in electronic form, video voyeurism, and partnership and collaboration of both individuals and
breach of confidentiality and leakage of data by government. There is much we can do to ensure a safe,
intermediary, e-commerce frauds like personation secure and trustworthy computing environment. It is crucial
commonly known as Phishing, identity theft and offensive not only to our national sense of well-being, but also to our
messages through communication services. So, penal national security and economy. Yet India has taken a lot of
provisions are required to be included in the Information steps to stop cybercrime but the cyber law cannot afford to
Technology Act, the Indian Penal code, the Indian Evidence be static, it has to change with the changing time.
Act and the Code of Criminal Procedure to prevent such
crimes”.39

Facts:
The Petitioners have raised a large number of points as to
the constitutionality of section 66A. According to them, first
and foremost Section 66A infringes the fundamental right to
freedom of speech and expression and is not saved by any of
the eight subjects covered in Article 19(2).40

Further, in creating an offence, section 66A suffers from the

vice of vagueness because unlike the offence created by
section 66 of the same Act, none of the aforesaid terms are
even attempted to be defined and cannot be defined, the
result being that innocent persons are also roped in. Such
persons are not told clearly on which side of the line they
fall; and it would be open to the authorities to be as arbitrary
and whimsical as they like in booking such persons under

36 Debarti Halder, Child Sexual Abuse and Protection Laws in

India (Universal Law Publishing, 1st edn.,2018)
37 Shreya Singhal v. Union of India [AIR 2015 SC 1523]
38 Ibid.
39 Akash dhanjani, “Case Brief Shreya Singhal v/s Union

of India, 2015” available at: https://lawbriefs.in/case-

brief-shreya-singhal-v-s-union-of-india-2015/ last
visited on: March 4. 2019
40 Information Technology Act 2000, India, available at: 41 Ibid.
http://www.mit.gov.in/itbill.asp (last visited on March 7, 42 Suhrith Parthasarathy “The judgment that silenced Section
2019 66A” The Hindu, March 8, 2019.

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