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CIS Comments on the National Strategy on Blockchain

Posted by Vipul Kharbanda & Aman Nair at Dec 31, 2020 12:00 AM |
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This submission is a response by the researchers at CIS to the report “National Strategy on Blockchain” prepared by Ministry of Electronics and Information Technology (MEITY) under the Government of India. 

We have put forward the following comments based on our analysis of the report.


  1. General Comments on the National Strategy

  1. There are currently a number of reports and policies on blockchain use across  departments, ministries and even states. The absence of a harmonised blockchain policy across all departments and institutions of government must be fixed. 

  2. There are inherent dangers with viewing blockchain as a silver bullet solution.  

  3. Informational concerns with blockchain are existent and policies must be designed to reflect these concerns and minimise their occurrences. 


  1. Section Specific Comments 

  1. Section 6.1 - There is a need for greater decentralisation and a shift away from a solely government operated blockchain 

  2. Section 6.2: 

  • The legality of blockchain also faces the hurdle of smart contracts 

  • The RBI decision to halt the use of cryptocurrencies was struck down by the Supreme Court 

  • The right to be forgotten exists as an extension of the right to privacy as well 

  1. Section 7 - There is a need for greater detail and granularity in the report’s analysis and in the suggestions and recommendations that it makes.