CONTEMPORARY LEGAL DEVELOPMENTS AND REFORMS

Introduction

India currently finds itself in the throes of one of the most far-reaching waves of legal reform post-Independence in recent history. In the last two years alone, the country has rolled out new colonial-era criminal statutes, consolidated twenty-nine distinct pieces of labour legislation into four unified statutory codes, and begun to enforce India’s first comprehensive data protection law. Each of these landmark developments follows an almost identical pattern: A foundational piece of legislation is introduced and then – over several years – a complex cascade of regulations, notifications, and adaptations at various levels of government slowly roll out. Today, as we write this article, each of the above processes is still ongoing. We explore them in turn below, starting with the Digital Personal Data Protection Act, 2023 (“DPDP Act”) on data privacy regulation, then discussing the newly adopted Labour Codes, before finally addressing the recently passed Bharatiya Nyaya Sanhita, Bharatiya Nagarik Suraksha Sanhita, and Bharatiya Sakshya Adhiniyam, which replace the Indian Penal Code, Code of Criminal Procedure, and Indian Evidence Act respectively.

This paper provides a survey of the most significant legal reform developments impacting the current regulatory landscape, focusing in particular on the regulation of artificial intelligence, data privacy law development, and various enforcements issues that are helping bind together disparate areas of focus.

The Digital Personal Data Protection Act: India’s First Comprehensive Privacy Law

The primary data protection regime governing data processing activities in India has historically been governed under section 43A of the IT Act, 2000 and the Sensitive Personal Data Rules issued in 2011. These rules are relatively modest compared to international counterparts. This landscape was dramatically altered when the DPDP Act was enacted in August 2023. However, until the corresponding rules came into effect on November 13-14, 2025, these provisions lacked enforceability. The notifications triggered key processes such as establishing the Data Protection Board of India (DPBI), an adjudicatory and enforcement body; setting up a framework for registering ‘Consent Managers’ who allow individuals to regulate their consents for various digital services; and prescribing more elaborate obligations relating to breaches, notices and Significant Data Fiduciaries, among other things.

In terms of enforceable rights, the DPDP Act affords Data Principals (individuals whose data is processed by organisations under this law), among other things, the right to know when and how their data was collected and used by the organisation, the right to request access to that data, the right to demand its deletion if necessary, the right to object to the processing of their data, and sometimes the right to nominate someone else who will act as their representative exercising all such rights. Further, the Data Privacy Board of India (DPBI) – the body charged with enforcing this legislation – possesses powers akin to those of many international equivalents. It can investigate violations of this law and impose levies of up to INR 250crore for serious breaches. These levies can then be appealed against before the Telecom Disputes Settlement and Appellate Tribunal. Importantly, there are extraterritorial provisions too: organisations processing the personal data of individuals in India – wherever they may physically reside – must also comply with DPDP obligations.

India Briefing notes that 2026 will see “a soft enforcement” from the DPBI as well (India-Briefing 2026). This means that DPBI officials should focus their time and energy primarily on providing advice and issuing cautions during this year rather than engaging in more adversarial activity through punitive proceedings. We expect the Consent Manager framework itself to get operationalised sometime between June and August 2026 while the registration window for Consent Managers should come to an end somewhere around November 2026. The hard enforcement of this law – complete with the whole penalty regime – is predicted to kick off around May 13-14, 2027 after which we’ll have reached the end of an 18-month transition period. But given what’s coming down the tracks in 2026, that last full year should allow sufficient time for companies to prepare structurally before facing any substantive scrutiny.

III. Labour Law Reform: Four Codes Replace Twenty-Nine Statutes

Labour law reform in India has been described as “the most far-reaching exercise in restructuring employment regulations undertaken by the nation in its history”. 4 Three main Codes came into force from 21 November 2025 replacing 29 distinct central labour statutes ranging in date of enactment between the early twentieth century and recent years – the Code on Wages, 20195; the Industrial Relations Code, 20206; the Code on Social Security, 20207; and the Occupational Safety, Health and Working Conditions Code, 20208. While repeal of the old laws was effective immediately upon the commencement of these codes, many of their operative provisions remained inoperative pending additional rules being made.

Rulemaking has seen significant advances as well with the ministry of labour and employment notifying its final central rules applicable to all codes – code on wages (central) rules, social security (central) rules, occupational safety, health and working conditions (central) rules & industrial relations (central) rules – on May 8, 2026. The rule introduces a new way of computing wages. A fixed daily minimum wage will be divided by eight hours to get the hourly wage that will be applied proportionally if workers have a workweek less than five days per week. “50 percent wages rule” introduced under these rules governs the structure of basic pay compared to their total compensation. This affects calculation of various benefits such as provident fund, gratuity, bonus etc., and employers are already restructuring salary packages ahead of implementation.

Implementation however is dependent upon individual state governments who will notify their respective Rules from time to time as per the Labour Law subject matter which lies on the Concurrent List of Indian Constitution. Implementation progress across States have been varied. As of Mid-2026, states such as Madhya Pradesh, Uttar Pradesh, Gujarat, Karnataka, Haryana, Uttarakhand, Jharkhand, Odisha, Bihar, Assam, Chhattisgarh etc have finalised their Rules for all four Codes. However, Major Industrial States i.e., Maharashtra, Tamil Nadu, Kerala, Punjab, Rajasthan, Telangana, Andhra Pradesh, and West Bengal are at draft level only. It should be noted that there is no announcement about any uniform / pan-India commencement date of these Rules by the Central Government. In fact, our Labour Law regime currently finds itself in the ‘stabilisation phase’ (as an Analysis Report stated) with few components e.g., gig worker contribution rates & compulsory Gratuity Insurance needing central notification.

Criminal Law Reform: The End of India’s Colonial-Era Codes

This was followed on 1st July 2024 when the Bharatiya Nyaya Sanhita (BNS), Bharatiya Nagarik Suraksha Sanhita (BNSS) and Bharatiya Sakshya Adhiniyam (BSA) replaced the Indian Penal code of 1860, the Code of criminal procedure of 1973 and the Indian evidence act of 1872 respectively. These reforms are the brainchild of the Committee for Reforms in Criminal Laws led by Prof. (Dr). Ranbir Singh who had presented their recommendations in June 2023 after getting the president’s assent in Dec 2023.

While this third pillar aims to reorient the entire criminal justice mechanism towards a victim centric and tech enabled process, it has provisions to set up a specific Chapter on crimes against women and children. Under this new law, all these matters will have to be concluded within two months from the date of recording of the information. Forensic experts would also have to visit the crime scene where there is a case involving serious crimes, and cases can be filed electronically via first information report and summons served electronically. What makes this new bill particularly interesting though, is that it recognizes the equal evidentiary value of electronic and digital documentation similar to physical documents under the BSA. This appears to be much needed especially since there’s such large amount of digital communications involved in modern day criminal activities. But what remains unchanged here is the fact that the very foundation of the penal laws continues to reflect a punitive approach although elements of restorative justice including community services as alternatives to prison sentence for some petty offenses were introduced too, according to PRS Legislative research.

Implementation continues to be a work in progress, as cases filed before July 1, 2024, remain governed by previous legal frameworks such as the IPC, CrPC, and Evidence Act to avoid retrospective application. This means that the country’s judiciary and police stations will operate on separate but related frameworks for several years going forward (Kanoon Advisors, 2026). According to an academic publication analysing the first six months of implementation, “police forces and lower courts have taken some time to adjust to the new processes,” while other parts of the laws have been “subjected to inconsistent interpretations by the courts” (Cambridge Core, 2026). Legal commentators’ writings from 2026 note that many people are still “unaware of the new law” introduced in 2024, with courts and law enforcement agencies continuing their adaptation process nearly two years into its existence.

Conclusion

These cases – taken together – reveal patterns in how India approaches its legal system’s modernisation over time. First, there is significant, if disparate, legislative change characterised by a focus on comprehensive overhaul implemented at speed. Second, these are also processes which will require long-term engagement from legal stakeholders due to accompanying rulemaking, notification processes, and necessary changes in institutions’ capacities. In many ways 2026 could be considered the most significant year yet for both data protection and labour reform (though this is likely to prove a transitional one), with the Data Protection Board of India beginning supervision and enforcement of the Digital Personal Data Protection Act and the two sets of labour codes waiting for their announcement of uniform commencement dates for implementation in all states respectively. Meanwhile the newly drafted criminal codes remain under further bed-down while carrying out existing functions in light of ongoing court cases brought using pre-reform legislation. As such “reforms” in India are seldom a single point in time; instead, legal professionals need to consider them an ongoing phenomenon requiring continual tracking and updating.

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