Net Neutrality in India (31 March 2015)


The Times of India wrote up a useful primer with a list of Trai’s 20 questions to consider:

  • Question 1: Is it too early to establish a regulatory framework for
    OTT services, since internet penetration is still evolving, access
    speeds are generally low and there is limited coverage of high-speed
    broadband in the country? Or, should some beginning be made now with
    a regulatory framework that could be adapted to changes in the
    future? Please comment with justifications.

  • Question 2: Should the OTT players offering communication services
    (voice, messaging and video call services) through applications
    (resident either in the country or outside) be brought under the
    licensing regime? Please comment with justifications.

  • Question 3: Is the growth of OTT impacting the traditional revenue
    stream of TSPs? If so, is the increase in data revenues of the TSPs
    sufficient to compensate for this impact? Please comment with

  • Question 4: Should the OTT players pay for use of the TSPs network
    over and above data charges paid by consumers? If yes, what pricing
    options can be adopted? Could such options include prices based on
    bandwidth consumption? Can prices be used as a means product/service
    differentiation? Please comment with justifications.

  • Question 5: Do you agree that imbalances exist in the regulatory
    environment in the operation of OTT players? If so, what should be
    the framework to address these issues? How can the prevailing laws
    and regulations be applied to OTT players (who operate in the
    virtual world) and compliance enforced? What could be the impact on
    the economy? Please comment with justifications.

  • Question 6: How should the security concerns be addressed with regard
    to OTT players providing communication services? What security
    conditions such as maintaining data records, logs etc. need to be
    mandated for such OTT players? And, how can compliance with these
    conditions be ensured if the applications of such OTT players reside
    outside the country? Please comment with justifications.

  • Question 7: How should the OTT players offering app services ensure
    security, safety and privacy of the consumer? How should they ensure
    protection of consumer interest? Please comment with justifications.

  • Question 8: In what manner can the proposals for a regulatory
    framework for OTTs in India draw from those of ETNO, referred to in
    para 4.23 or the best practices summarised in para 4.29? And, what
    practices should be proscribed by regulatory fiat? Please comment
    with justifications.

  • Question 9: What are your views on net-neutrality in the Indian
    context? How should the various principles discussed in para 5.47 be
    dealt with? Please comment with justifications.

  • Question 10: What forms of discrimination or traffic management
    practices are reasonable and consistent with a pragmatic approach?
    What should or can be permitted? Please comment with justifications.

  • Question 11: Should the TSPs be mandated to publish various traffic
    management techniques used for different OTT applications? Is this a
    sufficient condition to ensure transparency and a fair regulatory

  • Question 12: How should a conducive and balanced environment be
    created such that TSPs are able to invest in network infrastructure
    and CAPs are able to innovate and grow? Who should bear the network
    upgradation costs? Please comment with justifications

  • Question 13: Should TSPs be allowed to implement non-price based
    discrimination of services? If so, under what circumstances are such
    practices acceptable? What restrictions, if any, need to be placed
    so that such measures are not abused? What measures should be
    adopted to ensure transparency to consumers? Please comment with

  • Question 14: Is there a justification for allowing differential
    pricing for data access and OTT communication services? If so, what
    changes need to be brought about in the present tariff and
    regulatory framework for telecommunication services in the country?
    Please comment with justifications.

  • Question 15: Should OTT communication service players be treated as
    Bulk User of Telecom Services (BuTS)? How should the framework be
    structured to prevent any discrimination and protect stakeholder
    interest? Please comment with justification.

  • Question 16: What framework should be adopted to encourage
    India-specific OTT apps? Please comment with justifications.

  • Question 17: If the OTT communication service players are to be
    licensed, should they be categorised as ASP or CSP? If so, what
    should be the framework? Please comment with justifications.

  • Question 18: Is there a need to regulate subscription charges for
    OTT communication services? Please comment with justifications.

  • Question 19: What steps should be taken by the Government for
    regulation of non-communication OTT players? Please comment with

  • Question 20: Are there any other issues that have a bearing on the subject discussed?

C-DoT launches cheap, long-distance wifi/broadband technologies to bring Internet to (almost) every Indian

This issue has caught everyone’s attention in India now. The media are awake and alert. They’re, fortunately, taking a pro- net neutrality position. There’s a national campaign going on to send as many responses as possible to TRAI. It’s crossed more than 250,000 responses and this itself could mean that the issue will be taken up more seriously.

The Government is staying aloof from making any solid action. But hopefully in the coming days the conversation will be about putting in definitive laws about Net Neutrality, which do not exist for the time being.

The main conversation in the country today is around Airtel Zero, a zero-rated platform not different from I’m wondering if Mozilla has an official stance on zero-rating. Because as far as I see, it is a very debated topic and people are still fancying the idea that zero-rating could be a good thing in the long run. Evident in this video from Internet Governance Forum.

But I think with Firefox OS being targetted at people who have never used a smartphone (and Internet) a stance that supports zero-rating can not be feasible, unless Mozilla wants to partner with Telecom operators around the world. How can and FirefoxOS coexist?


India is facing the issue of destruction of Net Neutrality over the open web, which in turn will not keep the web open anymore.
Netizens from India in all capacity have taken this seriously. They have started talking about it, signing petitions, initiating campaigns and sending emails to TRAI about the support towards Net Neutrality.

As mozillains and supporters of the open web this issue affects us directly, hence we have decided to take active steps to help protect Net Neutrality in India.

Considering the practical impact we can have on people of India to support for Net Neutrality ais through starting a campaign with defined steps for mozillains to act upon. These steps are optional but necessary for one to measure the impact on educating the nation’s existing and potential internet users. Below are some action steps that you can follow to be an active part of the force protecting the Open Web.


  • Spread the news: We urge the mozillians and all the internet users to have conversations about Net Neutrality. Sharing news and latest developments about this topic will help us educate more people.

  • Send the petition email to TRAI: As of now over 300,000 emails have been sent to TRAI through
    The higher the number, the stronger the proof that India wants Net Neutrality.
    Encouraging your audience to email with comments to the 20 questions themselves.
    They can use the reference answers provided on

  • Documenting the effort: Document your activities talking about the diversity of your audience, the success of the effort, impact and participatory nature of the campaign. Personal thoughts, social media shares and pictures/videos are all welcomed.

More about Net Neutrality in India:


Meanwhile, the SaveTheInternet campaign has sent 600990 mails sent to TRAI, the NetNeutrality India handle reported.


Also, an interesting post was published on the other day; perhaps a bit dramatic, but explains the issues in laymen’s terms: “Poor Internet for Poor people: Why Amounts to Economic Racism.”

I think the most explosive statement from the post is: “Internet Dot Org neither offers the internet to its users—nor is a dot org, denoting a charitable organisation. It just seems to be a cloaked proxy for the Facebook Economically Disadvantaged User Acquisition Department.”


It is wonderful how Mozilla has not pitched in with a single word about zero-rated Facebook. Maybe because there are people who joined Mozilla from Facebook at the top rungs of policy teams. India will protect the Internet, with or without Mozilla’s help. I’m really sad that we’re gonna have to do it without Mozilla, though.

(No, I’m not very angry. I’m just trying to provoke responses :P)

Edit: These are my personal views and most probably does not represent Mozilla India community’s views.

Edit: Mozilla India has yet to form a view on this issue because the Mozilla India policy task force is only being formed. So.

Net Neutrality in India. We need to hear from Mozilla

Cross posting from netpolicy mailing list

Disclaimer: These are my personal views and I do not represent Mozilla India community. I represent the Open Web, though.

I joined netpolicy mailing list very recently on knowing that Mozilla does not have an official stance about zero-rating. On viewing the archives, I see that there have been limited discussions about W0 and

I am a from India, and India has recently been burning with the question of Net Neutrality. There is a discussion on advocacy discourse with some background information. 0

While I agree with Wikimedia foundation’s no-matter-what approach to get everyone free access to the sum of world’s knowledge, I can’t stand watching when they’re being misused by Facebook’s no-matter-what approach to get everyone using Facebook.

Imagine if Google tied up with local ISPs and said “free access to Google websites if
people use Google Chrome” and said their aim is to bring Internet to the next billion. Wouldn’t Mozilla be up and fighting on the day before such an announcement is made?

Then why is it that while Mark Zuckerberg goes on to mislead people that brings
“access to basic Internet services” 1, Mozilla remains silent?

I’ve been told that an official blog post about is being discussed. But I wonder where this is being discussed. If at all this mailing list counts, let me mark my opinion.

Since I am a medical student, I went through the list of health-related apps available on 2 and stood agape with horror for a while. There are three apps - one about pregnancy and motherhood, one about health, hygiene, common diseases, and one about Malaria. (And there’s one service for blood donation too) These fit in information that could well have fit palmphlets. I have learnd in my school that the poor or the disempowered cannot be expected to read palmphlets and improve their health on their own. What then is the purpose of these websites other than padding up Facebook so that Mr Zuckerberg can freely use the word “health” in his posts about

And I guess by “education” he means I am a volunteer at a rural school in Mysore, Karnataka. I’ve been constantly trying to bring broadband access to the school. But it’s too far from the city to have lines laid till there. So we’re still stuck with cellular operators. And the one connection we do have there is Reliance (who incidentally are Facebook’s partner in India for It is extremely slow.
Yet, students there use gmail to send emails to volunteers in the cities and these interactions have built strong bonds between them. These students are not well versed in English. Some of them can’t read even
their English textbook without help. But they still use Wikipedia to learn about things. The Kannada Wikipedia is not quite full of science/history articles which they need. Yet, we can ask them to use

But kids are kids. They don’t sit down and read. We’ve tried our best to give them questions, make them google for answers, get interested in stuff, and slowly learn their way on Internet. For example, there’s this guy who loves wildlife. He discovered a website called IndiaNatureWatch and learned a lot about
birds, snakes, etc. View his profile for the photos he captured 3.

I am proud to say that I won’t be letting anywhere near this school. Because the Internet we have, though it is slow and sucks, is much much better than the Internet Facebook’s planning to give the “poor”.

If you are in a developed country and you are still thinking that free Facebook can help poor people, I hope my experience will give you some ideas to the contrary.

There are organizations in India which work with the same set of people by empowering them digitally. IT for Change is one such organization. And its executive director has written this: “Commercial arrangements between telecom and internet companies are beginning to create “internet malls” that will give preferential access to a few internet companies. These structures will eventually undermine the public internet that we know and celebrate. Governments that are now ignorant of IT regulatory issues need to act soon on net neutrality so that the public internet remains in place.” 4

I hope Mozilla comes out with a strong voice against zero rating (at least in India).

Lover of the Open Web


I just posted a new discussion threat on zero rating and net neutrality in India here: Zero Rating and Net Neutrality


“Facebook Economically Disadvantaged User Acquisition Department”

That’s a great name. Can we make it a great acronym too?

Facebook System for Economically Disadvantaged User Capture and Exploitation

i.e. Facebook SEDUCE…



Very happy news. Mozilla has written a letter to the Indian Prime Minister about protecting net neutrality, including a warning against zero-rating as it is practised currently in India.

Blog posts:

I personally thank Mitchell Baker and everyone else who’s worked behind this policy position. And I apologize for all rude remarks I’ve made while these positions were being formulated :no_mouth:. You people are awesome.


Thank you, Akshay. It is no understatement to say that you, and the rest of the community that weighed in, helped to push our thinking. Thank you!


After the furore last month a committee was formed to give a report to Department of Telecommunications, Government of India.

This committee has released its report yesterday.

Official: Intro, full report, summary of recommendations.
Unofficial: Abridged version

Quick summary from the abridged version:

  • Licensing for domestic VoIP, no licensing for international VoIP, no licensing for messaging, no licensing for regular apps
  • zero rating to be allowed on a case by case basis by TRAI, TRAI should address complaints about NN violations
  • is bad because of collusion, content companies cannot play gatekeeper
  • Managed and enterprise services can be exempt from Net Neutrality requirements
  • Legitimate traffic management is allowed, but shouldn’t be app specific. Deep Packet Inspection to look at app and its content is not allowed.
  • Security is paramount and need to figure out how to intercept all traffic, need to look at security issues via interministerial consultations
  • Privacy is important but have to wait for a privacy law
  • Can include net neutrality clause in current laws instead of creating a new law
  • Search-Neutrality issues are important, but we’ll look at them later
  • Not looking at CDN, which are best left to be looked at under unfair trade practices law

Although there are some feel-good sentences in the report, it is riddled with practically difficult recommendations (like licensing for domestic VoIPs and not for international VoIPs) and could have been better in at least three ways as written here.


In response to the recent Committee Report on Net Neutrality by the Department of Telecommunications, Mozilla has filed comments (PDF) sent by Denelle Dixon-Thayer, General Counsel and Senior Vice President, Business Affairs.


Equal rating services or effectively low income pricing/tariffs are a fine idea but require state intervention to enable. Universal service is typically not cost effective for providers unless incentivized across the market. In the absence of regulatory intervention however, zero rating services still have a place as a useful tool for expand Internet access.


@Mozilla_Advocacy I have a query . Technically we know Equal rating is the open Internet . But going via the popular “zero rating” term, under DoT reports on net neutrality , does it fall under the category in which regulation is proposed . DoT report recommends an approach similar to OECD suggestions ie . Zero rating need to be allowed in case by case basis.

If that is the case , we may need to demand the policy addressing “equal rating” as a special category as mentioned in submission , and differentiate it with zero rating with more advocacy efforts


Just a reminder that equal rating is not the open Internet; it’s the “open Internet” in that country and without a VPN. Many, many states censor the Internet especially in the developing world.

While we might draw a comparison between the walled garden of zero rating services and open Internet of equal rating services, we need to remember that in actuality there are three flavors:

  1. Zero rating: Corporately censored and state censored
  2. Equal rating/“open”: State censored
  3. True open Internet: Uncensored


Major Update

A Major Telecom company is now offering Non-discriminatory zero-rating :slight_smile:
Happy to see Indutstry is changing


Agreed though the question in my mind is whether this policy would have been rolled out absent Facebook?


My thoughts on Free Basics and Net Neutrality