The Supreme Court will soon decide on the right to privacy case. Photo for representation: Reuters.

After listening to arguments for and against privacy as a fundamental right, the nine-judge Constitution bench of the Supreme Court has reserved its verdict in the case.

During the course of hearing, senior lawyer Kapil Sibal, representing the states of Karnataka, West Bengal and Puducherry in the privacy debate, argued that while privacy is not mentioned in the Constitution of United States of America and Australia, it is treated at par with a fundamental right.

Petitioners have argued in the Supreme Court that while the word 'privacy' is not mentioned in the Constitution, fundamental ideas of liberty and freedom cannot exist without privacy.

Before the Supreme Court decides on the right to privacy debate, take a look at how the world views privacy:

UNITED STATES OF AMERICA

Privacy is not exactly mentioned in the Constitution of the US, but the Fourth Amendment to the Constitution is largely seen as the one protecting the right to privacy.

The Fourth Amendement to the Constitution of United States states that "the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized".

Post WikiLeaks, concerns over privacy and data protection have seen a rise in US. According to a November 2014 study by Pew Research Centre on 'Public Perceptions of Privacy and Security in Post-Snowden Era', 91 per cent of the adults it surveyed agreed that consumers have lost control over how personal information is collected and used by companies.

EUROPE

The EU Data Protection Directive, adopted by the member countries of the European Union (EU) in 1995, looks after protection of personal data and regulates free movement of such data.

The European Commission is now bringing a new set of rules on data protection which will be enforced by the member countries of the European Union by May 2018.

The objective of the new rules, according to the European Commission, is to give citizens control over their personal data, and to simplify the regulatory environment for business.

Besides, Article 8 of the European Convention of Human Rights (ECHR) guarantees right to respect for private and family life. All members of the European Union are signatories to the ECHR.

The Article states, "There shall be no interference by a public authority with the exercise of this right except such as is in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others".

AUSTRALIA

The Privacy Act, 1988 regulates handling of personal information about individuals. The Act includes 13 Australian Privacy Principles (APPs), which regulate the use and access of personal data.

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