Submission to MHA regarding whitelist for Internet access in Jammu and Kashmir

The Bachchao Project and The Takshashila Institution made a joint submission to India’s Ministry of Home Affairs (MHA) based on our findings of a usability testing exercise conducted on the whitelist issued for Internet access in Jammu and Kashmir in January 2020. A copy of the submission has been uploaded here along with a summary of the questions raised by our findings.

The findings are available on Zenodo:

Shri Ajay Kumar Bhalla,
Home Secretary,
Ministry of Home Affairs,
Dated: February 19, 2020

Dear Sir,

Subject: Jammu and Kashmir Internet Whitelist

This communication is with reference to orders issued by the Home Department, Government of Jammu and Kashmir (dated January 14, 18, 24 and 31) regarding the Temporary Suspension of Telecom Services and enforcement of a whitelist of websites available for internet access in Jammu and Kashmir.

We have conducted a usability analysis of the 329 entries in the whitelist with the following results.

  • 20% of the entries were practically usable.
  • 23% of the entries were partially usable.
  • 47% of the entries were not usable in any meaningful way.
  • 10% of the entries could not be analysed as the information provided was inadequate/ incorrect.

The analysis demonstrated that this whitelisting approach is not technically feasible, especially for a large population, nor is it practically workable. It also simultaneously raised questions about the whitelisting exercise as a whole, which need to be urgently addressed by the Ministry of Home Affairs.

  1. What were the process and criteria applied to select these specific URLs/ services/ websites to be on the whitelist?
  2. What were the process and criteria applied to reject some services provided by the government from the whitelist?
  3. What were the process and criteria, if any, to reject websites and services that are similar to those whitelisted and those that provide the same or comparable services?
  4. How were the residents of Jammu and Kashmir informed about this whitelist, that these specific services/ websites had become accessible?
  5. Were recommendations sought from the Telecom Regulatory Authority of India (TRAI) with regard to the violation of Net Neutrality? If so, what recommendations did TRAI put forward?
  6. What were the criteria for blocking VPN services?
  7. What, if any, technical testing was conducted to ensure smooth operation of the whitelisted websites?
  8. What, if any, was the review process put in place for the list?
  9. In view of all the above questions, how will the authorised government officers “ensure implementation of these directions in letter and spirit,” as stated in paragraph 7 of the order dated January 14?

We have enclosed a document containing the following information for your perusal.

  • Executive summary
  • Background note
  • Summary of results
  • Questions with supporting information

The document also includes three addenda (in case further details are required).

  • Addendum 1: Detailed write-up about the method of testing, its limitations, our observations based on our findings, and questions and comments about the role of ISPs in implementing the whitelist.
  • Addendum 2: The test results and observations for each of the 301 entries in the whitelist contained in the order dated 24 January.
  • Addendum 3: The test results and observations for new entries made to the whitelist specified by the order dated January 31. The new entries had to be analysed separately since this order removed the ‘Field’ column resulting in a change in categorisation of the entries.

We seek your response(s) to the 9 questions listed in the submission.

Copies to:

  1. Shri Amit Shah, Minister for Home Affairs
  2. Shri Ravi Shankar Prasad, Minister for Communications, Minister for Electronics and Information Technology
  3. Shri Anshu Prakash, Secretary to the Department of Telecommunications
  4. Shri Ajay Sawhney, Secretary to the Ministry of Electronics and Information Technology
  5. Shri Shaleen Kabra, Principal Secretary to the Government, Home Department, Government of Jammu and Kashmir
  6. Shri R. S. Sharma, Chairman, Telecom Regulatory Authority of India (TRAI)
  7. Shri Sanjay Dhotre, Union Minister of State for Communication, and for Electronics and IT

Prateek Waghre
Research Analyst,
The Takshashila Institution

Rohini Lakshané
Director, Emerging Research,
The Bachchao Project

Questions about whitelist for Internet access in Jammu and Kashmir

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