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DPDP Rules, 2025 · Rule 22 of 23

Rule 22: Appeal to Appellate Tribunal

Rule 22 is where you go if you disagree with a Data Protection Board order — how to appeal, what it costs, and how the Appellate Tribunal is expected to run the process.

Effective from 13 May 2027Reviewed September 2026
CommencementEffective from 13 May 2027
DPDP Rules, 2025 · Rule 22 of 23

Quick summary

In plain terms: Anyone aggrieved by a Board order or direction can appeal to the Appellate Tribunal, filed digitally, with a fee payable via UPI or another RBI-authorised system (waivable at the Tribunal's discretion). The Tribunal isn't bound by the Code of Civil Procedure, is guided instead by natural justice, and can function as a digital office.

What Rule 22 says

  • Any person aggrieved by an order or direction of the Board may appeal to the Appellate Tribunal, filed in digital form as the Tribunal decides.
  • The appeal must be accompanied by a fee equivalent to that applicable under the Telecom Regulatory Authority of India Act, 1997, payable digitally via UPI or another RBI-authorised payment system, unless reduced or waived by the Tribunal's Chairperson at her discretion.
  • The Appellate Tribunal isn't bound by the Code of Civil Procedure, 1908, but is guided by principles of natural justice and can regulate its own procedure, subject to the Act's provisions.
  • The Tribunal can function as a digital office, exercising the same summons/ attendance/examination powers, without requiring physical presence.

Breaking it down

Three things worth knowing if you're actually considering an appeal:

Filing is digital by design. Consistent with the Board and Tribunal's overall digital-first approach (see Rule 20), appeals are filed digitally rather than requiring physical paperwork submission.

The fee has a real-world anchor — and a waiver route. Rather than inventing a new fee schedule, the Rule pegs the appeal fee to what's charged under the Telecom Regulatory Authority of India Act framework, paid through UPI or another RBI-authorised digital payment method. Critically, the Tribunal's Chairperson can reduce or waive that fee at her discretion — meaning cost isn't necessarily a fixed barrier to appeal.

Natural justice, not rigid civil procedure. The Tribunal isn't tied down by the formal Code of Civil Procedure that ordinary civil courts follow. It's expected to be guided by principles of natural justice instead — generally meaning a more flexible, faster process than a standard civil lawsuit, while still requiring fairness (like a genuine opportunity to be heard).

Why this rule matters

Knowing there's a real, accessible appeal route — digital filing, a capped and waivable fee, and a less rigid procedural framework than ordinary courts — matters for any organisation or individual who disagrees with a Board decision and needs to actually understand what pursuing that disagreement looks like in practice.

Real-world example

Example: A company appealing a Board penalty orderA company that believes a Board penalty order was based on a factual error decides to appeal. It files the appeal digitally as the Tribunal's process specifies, pays the prescribed fee via UPI, and prepares its case knowing the Tribunal will be guided by natural-justice principles rather than the full formal machinery of a civil court — and that hearings may well be conducted digitally rather than requiring in-person attendance.

Who needs to care about this rule

  • Any organisation or individual disagreeing with a Board order or direction and considering an appeal.
  • Legal teams weighing the cost and process of pursuing an appeal.

Common questions

Can the appeal fee be waived?
Yes — the Appellate Tribunal's Chairperson can reduce or waive the fee at her discretion.
Does the Tribunal follow the same procedure as a regular civil court?
No — it isn't bound by the Code of Civil Procedure, 1908. It's guided by principles of natural justice and can regulate its own procedure, subject to the Act.
Do I need to appear in person to pursue an appeal?
Not necessarily — the Tribunal can function as a digital office and conduct proceedings without requiring physical presence, similar to the Board itself under Rule 20.