# Evolution of Global Digital Forensics Laws and Emergent Challenges

Kaushik Thinnaneri Ganesan

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Kaushik Thinnaneri Ganesan. Evolution of Global Digital Forensics Laws and Emergent Challenges. 19th IFIP International Conference on Digital Forensics (DigitalForensics), Jan 2023, Arlington, VA, United States. pp.237-248, 10.1007/978-3-031-42991-0_13. hal-05517471

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# Evolution of Global Digital Forensics Laws and Emergent Challenges

Kaushik Thinnaneri Ganesan

Central Board of Indirect Taxes and Customs, Ministry of Finance, Mumbai, India
kaushik.tg@gov.in

**Abstract.** The proliferation of digital devices in the commission of crimes has presented unique challenges to law enforcement the world over. Academia and industry have developed tools to assist law enforcement in conducting digital forensic investigations. However, inadequate awareness of the legal provisions on the part of law enforcement and the absence of updated laws have resulted in situations where, despite the availability of technological support, offenders could not be prosecuted. It would also be productive if academia and industry could become more aware of the legal provisions governing electronic evidence and the legal challenges to technological solutions.

This chapter discusses the evolution of global laws pertaining to digital forensics with a focus on the admissibility of evidence derived from digital forensic procedures. The chapter also examines emergent challenges in digital forensics and efforts to enhance global cooperation.

**Keywords:** Laws · Cyber Crime · Electronic Evidence · Law Enforcement · Investigations

## 1 Introduction

The role of digital forensics in civil and criminal investigations has increased dramatically during the last decade. While law enforcement personnel recognize the importance of digital forensics, there appears to be a significant gap in following procedures laid out in the law for handling digital devices to ensure that the data obtained is admissible as evidence in court. Some of this is because applicable laws enacted some years ago may not address modern scenarios. Meanwhile, countries around the globe handle matters pertaining to electronic evidence in myriad ways.

This chapter pursues a holistic view of laws pertaining to digital forensics and the admissibility of electronic evidence in the United States, United Kingdom and India, with a more detailed analysis of Indian laws. Also, it critically analyzes emergent challenges in digital forensics from a policy perspective and what could be done to address them globally.
<figure><img src="image_3.png" /><figcaption>Fig. 1. Information obtained via digital forensics.</figcaption></figure>

## 2 Legal and Policy Issues

One might question the importance of legal and policy perspectives in digital forensics, which has become an intensely technical field involving state-of-the-art technological developments and cutting-edge research that power innovations in the field. However, the law enforcement perspective can help academicians and researchers better appreciate the challenges in translating technological advancements to perceptible actions by law enforcement, who are the principal beneficiaries of digital forensics research and development. For much too long, the legal and technological domains have not moved forward at the same pace. The unfortunate reality has prevented technological improvements in digital forensics from fully benefiting law enforcement. This chapter attempts to bridge the gap by raising awareness about legal and policy issues that govern the use of digital forensics by law enforcement and exploring legal solutions that could be devised to overcome the technological challenges.

## 3 Investigations

In an era where technology has become ubiquitous across society, offenses – whether cyber crime, murder, arson, tax fraud or smuggling – invariably involve the use of digital devices. This is because communications are *sine qua non* in the commission of most offenses, which makes it imperative to use digital devices. Indeed, digital forensics helps investigators ascertain one or more of the four key roles in the commission of offenses: planning, coordination, execution and transportation.

Figure 1 shows the information gleaned during investigations via digital forensics. The four information types include communications-related, location-related, application-usage-related and document-related information.
<figure><img src="image_4.png" /><figcaption>Fig. 2. Nature of electronic evidence.</figcaption></figure>

Figure 2 shows the nature of electronic evidence that is gleaned during in-
vestigations via digital forensics. The four main categories are proof of location,
proof of communications, proof of planning and/or collusion, and proof of com-
mission and/or abetting.

4 Legal Provisions on Evidence Admissibility

Five fundamental rules relating to electronic evidence must be addressed by legal
frameworks:

- **Admissibility:** Can data found on digital devices be used as evidence in a court of law?

- **Authenticity:** Does electronic evidence establish the facts in an indisputable manner?

- **Completeness:** Does electronic evidence convey the complete story without any gaps?

- **Reliability:** Was the manner in which electronic evidence was gathered beyond all doubt?

- **Believability:** Is the theory propounded by electronic evidence persuasive about the facts it represents?

This section examines the legal provisions in the United States, United Kingdom and India with regard to the five fundamental rules pertaining to electronic evidence.

4.1 United States Legal Provisions

Legal issues pertaining to the admissibility of electronic evidence in the United
States are primarily governed by the Federal Rules of Evidence [25]. Rules 104(a)
and 104(b) provide the underlying principles prior to proceeding to electronic
evidence authentication. Rule 104(a) gives the judge the power to decide on
the admissibility of evidence and covers questions such as whether a witness
is qualified, whether a privilege exists, whether evidence is relevant, whether it
constitutes hearsay, etc. Building on Rule 104(a), Rule 104(b) stipulates that
"[w]hen the relevance of evidence depends on whether a fact exists, proof must
be introduced sufficient to support a finding that the fact does exist. The court
may admit the proposed evidence on the condition that the proof be introduced
later."

Rule 702 requires that scientific and expert testimony must be reliable with
respect to the principles and methods used by experts as well as the application of
the principles and methods to the specific facts. The original test for admissibility
of scientific evidence is the Frye test (Frye v. United States, 1923) [24]. The Frye
test allows scientific evidence to be admitted if the science upon which it rests
is generally accepted by the scientific community.

The Federal Rules of Evidence as amended with effect from December 1,
2017 [11] recognize the availability of more than one option to a party seek-
ing to produce electronic records. Under the amended rules, a party can follow
the traditional route under Rule 901 or the route of self-authentication under
Rule 902 under which a certificate of authenticity is required. If a party chooses
not to claim the benefit of self-authentication, the party is free to come under
Rule 901, even if the evidence sought to be adduced is stored electronically. To
establish that an evidentiary item is authentic, Rule 901(a) requires that a pro-
ponent must produce admissible evidence "sufficient to support a finding that
the item is what the proponent claims it is." Rule 901(b) provides examples of
evidence that satisfy the standard of proof for establishing authenticity, includ-
ing testimony of a witness with knowledge, circumstantial evidence and evidence
describing a process or system that shows it produces an accurate result [10].

Reference is made to Rule 902 [11] – evidence that is self-authenticating and,
especially, to sub-rules of Rule 902. Rule 902(13) allows the use of a certifica-
tion to authenticate evidence generated by an electronic process or system (e.g.,
website content, data generated by an app or electronic entry/exit records in a
security system). Rule 902(14) authorizes a certification to authenticate a digital
copy of data taken from a device or system (e.g., mobile phone or hard drive).

The U.S. Rules of Evidence enumerate how electronic records are required
to be certified and where certificates are required to make them admissible in
a court of law. However, the rules do not specify the types of records that are
covered. Furthermore, they leave open the question of who is competent to issue
the required certification.

## 4.2 United Kingdom Legal Provisions

The United Kingdom was one of the first countries in the world to pass legislation pertaining to the admissibility of electronic evidence. Section 5 of the United Kingdom Civil Evidence Act of 1968 deals with the admissibility of statements
produced by computers [21]. This act has since been replaced by the United Kingdom Civil Evidence Act of 1995 that permits hearsay evidence [22].

Electronic evidence is accepted in civil and criminal trials in the United Kingdom. With regard to the actual evidence stored on digital devices, computer records are admissible as evidence in court by virtue of Section 3 of the Civil Evidence Act of 1995 [22]. Under the Criminal Justice Act of 2003, the court has the discretion to refuse to admit a business or other document under certain circumstances [14]. In any case, evidence contained in a digital device can be considered to be real evidence and is generally considered to be admissible. Specifically, the Police and Criminal Evidence Act of 1984 defines electronic evidence as "all information contained in a computer" [14].

Pertinent to this discussion is the 1985 case of Castle v. Cross [17], where the court held that a printout from a computerized breath-testing device was admissible evidence. Another is the R v. Shephard case of 1988 [13] in which records from till rolls in a shop linked to a central computer were produced to prove that items in the possession of the accused had not been billed and had, therefore, been stolen by the accused. In fact, the court held that if it could be shown that the computer was functioning properly, the records could be admitted as evidence. Finally, in the Intercity Telecom Limited and Anor v. Sanjay Solanki case of 2015 [2], the court accepted evidence in the form of digital devices such as laptops, iPads and USB drives containing confidential information belonging to the company.

## 4.3 Indian Legal Provisions

The Indian Evidence Act of 1872 as amended is the country's primary legislation that addresses issues governing the admissibility of evidence [8]. Section 65B of the Indian Evidence Act deals with the admissibility of electronic records. However, a lesser-known fact is that the amended Indian Evidence Act was not the first piece of Indian legislation to address the issue of electronic evidence. The Customs Act of 1962 as amended, which regulates all matters of policies and duties pertaining to the importation and exportation of goods, contains a provision about the admissibility of microfilms, facsimile copies of documents and computer printouts as documents and as evidence [7]. In fact, Section 138 of the Customs Act could be read as a precursor to the current Section 65B of the Indian Evidence Act.

A similar provision exists in the amended Central Excise Act of 1944, which deals with issues pertaining to Central Government excise duties on goods manufactured or produced in certain parts of India [6]. Section 138C of the Customs Act and Section 36B of the Central Excise Act were inserted vide Notification No. 18/88-C.E. (N.T.) dated June 29, 1988 by Section 13 of the Customs and Central Excise Laws (Amendment) Act of 1988 (Act 29 of 1988). However, Section 65B of the Indian Evidence Act was inserted vide Section 92 of the Information Technology Act of 2000 (Act 21 of 2000) [9]. Section 397 of the Companies Act of 2013 was inserted vide S.O. 902(E) dated March 26, 2014 [4].
<figure><img src="image_5.png" /><figcaption>**Fig. 3.** Evolution of electronic evidence laws in India.</figcaption></figure>

Most recently, the Central Goods and Services Tax Act of 2017, India's federal legislation providing for levy and collection of tax on the intra-state supply of goods and services, introduced a much-improved provision to address the issue of admissibility of electronic documents as evidence [5]. Figure 3 presents a timeline of the evolution of electronic evidence laws in India.

Section 138C of the Customs Act, Section 36B of the Central Excise Act and Section 65B of the Indian Evidence Act as amended have their origins in Section 5 of the United Kingdom Civil Evidence Act of 1968 [21], which was enacted in the era of mainframe computers, when personal computers were rare and the Internet and smartphones were figments of imagination. Of course, the nature of offenses that could be committed using mainframes were drastically different from the cyber crimes of today.

In 2020, the Supreme Court of India delivered a major judgment in the appellate case of Arjun Panditrao Khotkar vs. Kailash Kushanrao Gorantyal and others [19]. Specifically, the court held that “the major jurisdictions of the world have come to terms with the change of times and the development of technology and finetuned their legislations. Therefore, it is the need of the hour that there is a relook at Section 65B of the Indian Evidence Act, introduced 20 years ago, by Act 21 of 2000, and which has created huge judicial turmoil, with the law swinging from one extreme to the other in the past 15 years.”

It is worth mentioning here that the most recent legislation passed on the subject of admissibility of electronic evidence, namely Section 145 of the Central Goods and Services Tax Act of 2017 [5], is a much-simplified version of the law that focuses on the main aspect of electronic evidence. In particular, it establishes the authenticity of electronic evidence by placing reliance on a certificate to identify the document containing the statement and describing the manner in which it was produced, and also giving the particulars of any device involved in producing the document. This law provides a simpler and more effective framework for dealing with electronic evidence that could be emulated by other nations to deal with the admissibility of electronic evidence.
# 5 Indian Challenges and Solutions

This section discusses some challenges imposed on law enforcement agencies by current laws and offers proposals for addressing the challenges.

## 5.1 Agency Challenges

Key challenges faced by Indian agencies include issues related to primary versus secondary evidence and practical issues encountered during investigations.

**Primary and Secondary Evidence** The key provision governing all Indian laws pertaining to the admissibility of electronic evidence is the issuance of a certificate under the relevant section(s) to authenticate and/or certify the generated evidence. The Supreme Court of India has ruled that a certificate is required only when a secondary copy of evidence is relied upon and submitted as evidence in a court of law [19]. Going forward, the submission of original digital devices will be increasingly challenging due to the volatile nature of electronic data. This is exacerbated by the fact that Indian trials commence many months or years after the occurrence and detection of the actions in question.

Relying on the original devices until they are to be exhibited as evidence is problematic. One problem is that there is no guarantee that devices would function properly after the passage of time. After seizure and forensic analysis, digital devices are sealed and maintained in secure locations until trial. Digital devices typically need to be used regularly to function properly. Prolonged non-usage is likely to render the devices unusable and may even lead to data loss.

Another problem is that some courts, upon reviewing applications filed by accused parties whose devices have been seized by law enforcement agencies, have ordered that the original devices be returned to their owners after cloning the devices. The increasing emphasis on the personal rights of individuals will lead to legal challenges to the retention of original devices by law enforcement agencies and the possibility exists that device retention may even be discontinued in time.

**Investigations** Prevailing Indian laws related to electronic evidence also pose practical challenges in investigations by law enforcement agencies. These challenges are faced during investigations in other countries as well:

- **Password/PIN Code Sharing:** A common problem faced by law enforcement during investigations is the non-cooperation of accused parties with regard to sharing passwords and PIN codes for unlocking digital devices. This issue came to the fore in the aftermath of the 2015 terrorist attack in San Bernardino, California, and, more recently, in the 2019 terrorist shooting incident at the Pensacola Naval Air Station in Florida. While courts have come to the aid of investigating agencies by issuing orders to enable the unlocking of phones and other digital devices, equipment manufacturers, most
notably Apple, have expressed reluctance and have appealed against such orders.

- **Cloud Data Recovery:** Another major challenge faced during investigations is the recovery of data from the cloud. When accused parties refuse to cooperate in providing access to cloud data, law enforcement has no recourse but to request cloud service providers for access. Some major service providers may provide metadata. However, the vast majority of providers are located outside India, and due to the lack of jurisdiction, investigators are forced to resort to tedious and time-consuming procedures such as mutual legal assistance treaties and/or letters rogatory to legally procure cloud data. These procedures often take many years and require persistent follow-up efforts with overseas authorities. Often, even if the data is received, domestic time limits come into play. For example, a chargesheet or show cause notice may have already been filed, which invalidates the cloud data obtained from abroad from being used as evidence.

- **Deleted Data Coverage:** Modern digital forensic software helps in recovering data that has been deleted from digital devices, specifically from instant communications applications used on smartphones. However, the law is silent on whether deleted data that has been recovered is admissible in a court of law because this is due to technological developments that could not be conceived even a few years ago. Often, deleted data plays a crucial role in establishing the involvement of an individual in criminal activity. Moreover, it has been noticed by investigators that, in many cases, offenders tend to delete critical documents/chats from their smartphones to prevent law enforcement from recovering crucial evidence.

# 6 Proposed Solutions

The challenges and issues discussed above should be addressed more by legal solutions than technical solutions. Some proposals are:

- **Password/PIN Code Sharing:** A commonly-held misconception is that forcing an individual to part with the password or PIN code for unlocking a device is akin to forcing the individual to give evidence against himself/herself (i.e., self-incrimination). In fact, not providing a password or PIN code to enable law enforcement to conduct a legitimate investigation is more akin to withholding the key to a safe that is in the custody of an accused rather than refusing self-incrimination.

One of the High Courts in India (just below the Supreme Court of India in the judicial hierarchy) has relied on the Indian Code of Criminal Procedure of 1973 pertaining to persons who refuse to provide access to conduct physical searches of property [12]. Using the analogy, the court ruled that a magistrate may order an individual to part with a password or pattern to enable law enforcement to conduct a search of data contained in a digital device. Similar orders have also been issued by U.S. courts to enable law enforcement to access digital devices during the course of their investigations [20].
Be that as it may, it would preferable to enact legal provisions that mandate
individuals to provide passwords, PIN codes and biometric information to
enable electronic evidence to be accessed during investigations conducted by
authorized government agencies. This would eliminate any ambiguity with
regard to cooperating with investigating agencies seeking access to evidence
residing in digital devices. In the event that a digital device owner or pos-
sessor of the password, PIN code or biometric information is unavailable or
unable to provide them, the original equipment manufacturer would be re-
quired to unlock the device to facilitate the investigation. A global consensus
among law enforcement agencies would help achieve an amicable resolution
with technology giants such as Apple after impressing upon them the need
for cooperation with law enforcement worldwide.

- **Cloud Data Recovery:** Much of the cloud data sought by law enforcement around the world resides in a few countries such as Canada, United States and Ireland. Some countries have enacted or are enacting data protection legislation, but these efforts are focused more on protecting personal data than providing law enforcement with access to data during investigations involving overseas jurisdictions. Some multi-national corporations such as Google and Microsoft have begun to cooperate with overseas law enforcement agencies by providing them access to some basic data and metadata via law enforcement portals. However, this is more polite support than outright cooperation in investigations. Consequently, the utility of the basic data and metadata is limited and law enforcement agencies have to rely on the tedious and time-consuming routes of mutual legal assistance requests and letters rogatory. The U.S. Clarifying Lawful Overseas Use of Data (CLOUD) Act [15] covering cross-border access by law enforcement to electronic communications held by private companies is a major piece of legislation that facilitates U.S. law enforcement access to data located outside the United States. It is important to explore a global data-sharing agreement on the lines of the CLOUD Act to enable law enforcement around the world to access cloud data during investigations. The instruments could be amendments to existing mutual legal assistance treaties or a new multilateral treaty that deals only with the issue of sharing electronic data.

- **Deleted Data Coverage:** The term “electronic record” is defined in India’s Information Technology Act of 2000 [9] as “data, record or data generated, image or sound stored, received or sent in an electronic form or microfilm or computer-generated microfiche.” A plain reading of this definition seems to imply that deleted data is not covered under the ambit of an electronic record. Therefore, it would be worthwhile to consider amending the definition to include deleted data recovered using digital forensic analysis software on a digital device. Countries should also examine ways to ensure that deleted data is included in their definitions of “data” or “record” that can be used as evidence in courts of law.
## 7 Enhancing Global Cooperation

At its tenth session in October 2020, the Conference of the Parties to the United Nations Convention against Transnational Organized Crime adopted Resolution 10/4 that “request[ed] the United Nations Office on Drugs and Crime, within its mandate, to continue to provide technical assistance and capacity-building to member states, upon request, to support their capacity to prevent and combat transnational organized crime, including through the following: (...) (d) The updating, as necessary, of model instruments and publications, such as the guide on current practices in electronic surveillance in the investigation of serious and organized crime developed by the United Nations Office on Drugs and Crime in 2009 and the model law on mutual assistance in criminal matters developed by the Office in 2007.” Subsequently, the Model Law on Mutual Assistance in Criminal Matters was amended to incorporate a section pertaining to assistance in relation to electronic evidence [23]. New provisions have been inserted about the production of stored computer data in emergency situations and relevant definitions have been updated to reflect the state of the art. New provisions concerning the treatment of electronic evidence by a nation state following a foreign request have also been inserted. This model law could be used as a reference point to amend all mutual legal assistance treaties to encourage and simplify global cooperation with regard to electronic evidence.

## 8 Conclusions

Information technology and electronic evidence laws are evolving and leave considerable scope for interpretation in various judicial forums. There is a long way to go before the interpretation of electronic-evidence-related aspects is uniform and open issues are settled. Therefore, the onus is on governments to draft laws and provisions that are easy to understand and use, primarily by law enforcement involved in investigations and related activities. Additionally, laws dealing with electronic evidence need to be reviewed regularly and amended to take into account technological developments and ensure that justice is served. Better and closer working relationships between researchers and law enforcement must be instituted to create blended technological and legal solutions that address emergent challenges in the digital forensics domain. It is also important to keep in mind that no matter how advanced technologies may develop, as long as allied laws pertaining to electronic evidence do not keep pace with the developments, it would not be possible for the full benefits of technological advancements to be realized in ensuring that justice is done.

The views expressed in this chapter are those of the author, and do not reflect the official policy or position of the Central Board of Indirect Taxes and Customs, Ministry of Finance or Government of India.
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