Submissions to the Government

Narayan Chamber of Policy (NCP) actively responds to government consultations on upcoming new regulations and proposed amendments to existing regulations. Evidence-based submissions, and clause-by-clause suggestions help our submissions to stand out from others.

Our Submissions 

Consultation Paper on Unified Health Interface

Pursuant to the National Health Policy (NHP) and the National Digital Health Blueprint (NDHB), the National Health Authority (NHA) now proposes to create a Unified Health Interface (UHI), as a part of the National Digital Health Ecosystem (NDHE). The objectives and vision of UHI are well-intentioned, and do well on several counts, such as:

  • Envisioning an Open Network for Digital Health Services as a part of the NDHM;
  • Identifying the incentives and disincentives of joining UHI for different stakeholders;
  • Listing the features and services envisioned to be part of the UHI;
  • Discussing the development, governance and management of UHI; among others.

However, they have scope for improvement, basis our submission. (Read More)

Draft Drone Rules, 2021

The notification of the Unmanned Aircraft System Rules, 2021 (UAS rules), earlier this year in March, had met with immense resistance from stakeholders of the drone industry. The same reeked of License Raj, given its requirement of applying for numerous certificates and permits. Accordingly, the UAS rules were argued to be stifling Research & Development (R&D), hindering startups in the industry, and restricted foreign companies from operating drones, thereby creating roadblocks for foreign investments.

Now, recognising the immense potential of economic growth and employment generation offered by the drone industry, the Ministry of Civil Aviation (MCA) has
prepared the draft Drone Rules, 2021 (draft rules), which are set to replace the UAS rules. These draft rules do better than the UAS rules in providing an enabling environment for the drone industry. However, the rules can be further improved by incorporating the recommendations given in our submission. (Read More)

Proposed Amendments to Consumer Protection (E-Commerce) Rules, 2020

Despite notification of the Consumer Protection (E-Commerce) Rules, 2020, various stakeholders alleged that large e-commerce entities are adopting unfair trade practices, which may have an adverse impact on consumer welfare. These include: product search results manipulation, preferential treatment to some sellers, marketplace e-commerce entities having indirect stake in some sellers on their platform, selling goods close to expiration, predatory pricing, among others.

Various amendments have now been proposed in the Rules to curb such malpractices. While the proposed amendments do well in in promoting transparent information disclosure for
consumers, and protecting consumers against manipulative search indexes, there exists various lacunas in them. These have been captured in our submission. (Read More)