During 2021, various High Courts across India have seen an increase in writ and civil litigation seeking to obtain a ‘Right to be forgotten’ (RTBF), usually claiming it as a facet of ‘right to privacy’ enshrined in Article 21 of the Indian Constitution, after a Nine-Judge Constitution Bench of the Hon’ble Supreme Court had previously declared privacy as a fundamental right in Justice K.S. Puttaswamy (Retd.) vs. Union of India, (2017) 10 SCC 1 (‘Puttaswamy Judgment’).