DISMANTLING THE GDPR HEGEMONY: INDIA'S DPDP ACT AND THE RISE OF LEAN DATA GOVERNANCE IN THE GLOBAL SOUTH

For nearly a decade, the European Union’s General Data Protection Regulation (GDPR) has been heralded as the undisputed universal gold standard for data protection, prompting an aggressive wave of legal transplantation across developing nations. This article challenges this Eurocentric hegemony by analysing India's Digital Personal Data Protection (DPDP) Act, 2023, alongside its finalized DPDP Rules (2026), as a revolutionary counter model. India has rejected the GDPR's hyper bureaucratic, litigation heavy framework in favour of a Lean Data Governance architecture. While the GDPR relies on individual notice and consent compliance mechanisms that systematically fail in developing economies due to stark digital literacy and enforcement asymmetries thus the DPDP Act leans into technology-embedded law. Using a Third World Approaches to International Law (TWAIL) framework, this article evaluates how India’s model shifts the regulatory burden off vulnerable individuals and onto architectural fiduciaries.