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This article is written by Aboli Nimbalkar, pursuing Diploma in Advanced Contract Drafting, Negotiation, and Dispute Resolution from LawSikho. The article has been edited by Ruchika Mohapatra (Associate, LawSikho) and Indrasish Majumder (Intern at LawSikho).

This article has been published by Abanti Bose.


The pandemic has increased the dependency of the world on the online domain. Right from schools to parliamentary sittings, everything has gone virtual. It is no surprise then that the online world has created all sorts of possibilities to harness and E-commerce is one such area. E-commerce is the buying and selling of goods, services, transfer of data or funds over an electronic network. There are several platforms like websites, portals and applications which provide an interface for the users to interact with the service providers.

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When we think of E-commerce, the very first thing that comes to mind are the well-known names like Amazon, Myntra and Flipkart. But these platforms are only a subset of the larger sphere of E-commerce business models, of which there are at least 6. These are as follows:

1.B2C: Business-to-ConsumerA business sells its products or services directly to a customer through its own website.Example: Domino’s website
2.C2B: Consumer-to-BusinessWhere an individual caters his/her services to multiple business ventures.Example: Upwork
3.B2B: Business-to-BusinessA business sells its products or services through an intermediary to another business or venture.Example: IndiaMART
4.C2C: Consumer-to-ConsumerWhere consumers cater to other consumers through a website.Example: eBay, OLX
5.B2A: Business-to-AdministrationWhere businesses cater to Administration/Government.
6.C2A: Consumer-to-AdministrationWhere consumers interact with the government through a website/portal/application.

In this article, we will be focusing on the Consumer-to-Administration type of model as it is playing out in India, its role in Indian e-governance initiatives, the potential uses of C2A facilities, the repercussions it might have on data protection and the privacy issues, and the provisions of the PDP Bill, 2019 regarding the same.

What is Consumer to Administration (C2A) model?

C2A is defined as the e-commerce model where consumers utilize electronic means to reach out to the administration (local government/authorities). Every activity where a consumer avails of a public service or interacts with the government/authorities through a website, an online portal or a mobile app can be considered as the C2A model.

Following are the examples of Government of India initiatives for public service delivery i.e. C2A structures:

  • Government Services: application for PAN card, Aadhar Card, Voter-ID, booking railway tickets through IRCTC.
  • Health: COWIN portal for vaccination, National Digital Health Mission.
  • Tax: filing tax returns online, paying GST.
  • Bills: payment of electricity bill, payment of water bill.
  • Education: education provided by public institutions, central universities, NPTEL etc.

An amalgamation of technology and public services

The global scenario is fast changing with the introduction of new technologies every single day. It has become prudent on the part of organisations and institutions to keep up their pace and come up with new ways to connect to their audience. Technology has changed the scope of Indian e-governance as well. The Indian Government launched the National e-Governance Plan (NeGP) in 2006. The Digital India initiative and demonetisation drive gave further impetus to increase the scope of online public service delivery. 

As the COVID-19 pandemic began and it became too risky for citizens to physically visit government offices, schools, colleges and expose themselves to the virus, it gave a boost to the use of contactless digital technology for service delivery across India. The World Economic Forum has called it India’s “Digital Reset”. Online education and work-from-home provisions were a part and parcel of it. The announcement of the lockdown by the authorities nudged the country towards adapting digital methods of communications. The Aarogya Setu app was used to determine and track the spread of infection using real-time data monitoring. COWIN-portal was started for registrations and management of vaccine delivery. During the 2nd wave of the pandemic in India, some states managed the supply of supplemental oxygen and hospital beds using apps and portals which were updated in real-time.

The use of technology and service delivery was seen at local levels as well. For example, Pimpri-Chinchwad used Integrated Command and Control Centres (ICCC) to geo-locate COVID cases, determine open pharmacies and control hospital capacity using monitors and drones. The broader picture shows that the government response to the pandemic was heavily dependent on the internet and digital means. The reliance on online service delivery has also helped bypass the legacy bureaucracy, complacency and red-tapism that is usually seen in government offices. Public confidence in using digital service delivery mechanisms has certainly been on a rising trend since the pandemic.

Potential applications of C2A model : innovations in public service delivery

It is pertinent to understand what the general public’s aspirations are to cater to its demands. Digital mechanisms provide useful tools to the government to analyse it. Data collected using C2A systems can be used to understand the lacunae in the service delivery by analysing the citizen-generated data using new technologies like big-data analytics. This can be then used to address the grievances and improvise the service delivery. Such exercise can create a constant feedback loop between the public and the government.

It can also be an effective means of authentic information dissemination directly to the consumer on their hand-held devices, especially when it comes to Public Health Advisories and last-mile outreach for government initiatives. Tele-medicine services become the need of the hour while tackling contagious diseases and large-scale lockdowns. Local and state governments in coastal areas use cyclone warning SMS alerts to inform the fishermen and residents in the area to evacuate in case of an incoming storm. Similarly, IFLOWS-Mumbai was developed as a flood-warning system using GIS technology to create alerts for civic bodies and residents.

Perhaps the best use of C2A can be the decentralisation of governance and participation of every last person that the authorities are supposed to serve. City-planning and traffic management might be promising areas where data could be used to improvise service delivery. The untapped potential of the C2A mechanism can be harnessed using emerging technologies like multi-source data aggregation, cloud services, big-data analytics, internet-of-things and artificial intelligence, which will be able to help in streamlining the public service delivery mechanisms.

Efficiency of C2A : what can be done to improve?

While it is true that the online medium was relied on heavily by the government to respond to the COVID-19 pandemic, it also highlighted the existing digital divide in the country. Many children from rural India could not attend online school due to the non-availability of an internet connection, or a smartphone or a laptop. 

Telecom Regulatory Authority of India’s 2020 report depicts that only half the country’s population has access to decent internet connection and the UN E-Government Development Index (EGDI), 2020 ranked India 100 out of 193 countries which shows that there is a long way to go to truly cater to the unserved public. This mandates proper infrastructure provision on part of the government, starting from the continuous electricity supply, seamless internet connectivity through last-mile broadband connections and enhancing digital literacy. There is also a need to remove language barriers that hamper the non-English speaking population’s access to digital services.

Data protection : Personal Data Protection Bill, 2019

As citizens have started engaging with C2A services on a massive scale, the question of data security and privacy has come up time and again. There are looming risks of identity-theft, phishing scams, mass surveillance, data-mining and targeted advertisements while navigating the online world. To protect the personal data of Indian users on the internet, the Personal Data Protection Bill, 2019 was introduced in the Lok Sabha. The Bill governs the processing of personal data by the government as well as domestic and foreign companies. It speaks of the rights of individuals (called ‘data principals’) when it comes to their consent to management of their personal data. It also mandates the setting up of a Data Protection Authority to ensure compliance of all stakeholders with the provisions of the Bill. It also speaks of offences and punishments for violation of its provisions.

On the other hand, the Bill also creates concerns as it provides exemptions to government agencies from the provisions of the Bill itself on the grounds of security of the state, public order, sovereignty and integrity of India, incitement to cognisable offence, etc. This raises questions on the extent of the outreach of government agencies, mass-surveillance activities by the government itself and the potential threat to the democratic foundations of India if such exemptions are used to curb dissent in the name of sedition.


The COVID-19 pandemic has changed the course of history. It has made the boundaries of the virtual world and physical world blurry. As the online arena brings many opportunities to engage with the environment around us, it also creates increased risks for its users when it comes to data generation and handling, digital footprint created by individuals and also the issue of the right to be forgotten. It will be interesting to see how the Personal Data Protection Bill, 2019 is shaped to address the concerns posed by emerging areas of C2A interaction.



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