In counter-comments to TRAI, the Internet Freedom Foundation and the Centre for Internet and Society argued against telcos getting more flexibility in enforcing Net Neutrality. "We strongly disagree with industry submissions requesting light-touch regulation and excessive exceptions," IFF said. "It is apparent that such recommendations are essentially negotiating for the flexibility to discriminate between different classes of internet traffic." "The regulator should broadly define what comprises reasonable TMPs, and set out clear guidelines which would determine the reasonableness of any method adopted by the ISPs," CIS said in its filing, endorsing Stanford law professor Barbara van Schewick's comments. IFF similarly called for "clear and narrowly defined criteria for exceptions to the net neutrality principle to limit misuse". Blocking shouldn't be done based on any legal order IFF and CIS both stated that site blocking shouldn't be done on the basis of just any legal order, but only those from DoT under the law. "[T]he relevant authority must recognize the existing legal framework of blocking in India, which is governed by section 69A and section 79 of the Information Technology (IT) Act, and mandate that only blocking pursuant to orders under these sections would comprise as a reasonable form of TMP," CIS said. The filing cited the inconsistent blocks in early 2019 of Reddit, Telegram and Indian Kanoon, saying that the DoT was not even in the know about why the latter was blocked. Specialized services shouldn't be an excuse: "Specialised services exception can be a loophole through which normal services/applications…
