Telecommunications Land Policy: Telegraph Act, Tower Installation, and Fiber Network Rights

Introduction

India’s telecommunications infrastructure development operates within a sophisticated legal framework that has evolved from colonial-era legislation to contemporary digital infrastructure requirements. The telecommunications land policy encompasses statutory provisions governing right-of-way access, tower installation procedures, and fiber network deployment across public and private properties. This regulatory architecture balances infrastructure development imperatives with property rights protection while facilitating India’s digital transformation objectives.

The legal foundation for telecommunications land policy traces its origins to the Indian Telegraph Act, 1885, which remains partially operative despite recent legislative developments. The enactment of the Telecommunications Act, 2023 and subsequent Telecommunications (Right of Way) Rules, 2024 represents a paradigmatic shift toward modernized telecommunications infrastructure regulation. These developments reflect government recognition of telecommunications infrastructure as essential public utility requiring streamlined land access mechanisms.

The telecommunications sector’s land requirements differ fundamentally from traditional infrastructure projects due to the distributed nature of network architecture, minimal land footprint requirements, and technological evolution demanding flexible access arrangements. Current estimates suggest that India requires substantial expansion of telecommunications infrastructure to achieve digital connectivity objectives, highlighting the importance of a clear telecommunications land policy to govern land access and compensation mechanisms.

Historical Legal Framework: Indian Telegraph Act 1885

Foundational Statutory Provisions

The Indian Telegraph Act, 1885 established the fundamental legal framework for telecommunications land policy in India, conferring exclusive privileges to the Central Government regarding telegraph establishment and operation. Section 4 of the Act grants the Central Government exclusive privilege to establish, maintain, and work telegraphs within Indian territory, subject to provisions for licensing private operators under Section 4A. This monopolistic framework creates the legal basis for telecommunications infrastructure development through governmental authority.

Section 10 of the Telegraph Act empowers telegraph authorities to place and maintain telegraph lines on, under, or over any immovable property [1]. The provision requires telegraph authorities to follow prescribed procedures for taking possession of land for installing and maintaining telegraph lines and posts. Telegraph authorities possess limited powers restricted to installation and maintenance purposes, with obligations to cause minimum damage and provide adequate compensation to affected property owners.

The procedural framework under Sections 12 through 18 of the Telegraph Act governs property access for telecommunications infrastructure. Section 13 requires telegraph authorities to provide advance notice to property owners before commencing work, except in cases involving public roads or railways. The provision mandates consultation processes and establishes dispute resolution mechanisms through appropriate authorities where disagreements arise regarding compensation or property access.

Powers and Limitations of Telegraph Authorities

Telegraph authorities exercise specific powers under the 1885 Act while operating within defined limitations regarding property rights interference. Section 16 addresses property other than that owned by local authorities, requiring telegraph authorities to obtain consent from property owners or follow prescribed procedures for compulsory access. The provision establishes compensation mechanisms for property damage and creates legal obligations for minimal interference with existing property uses.

Section 17 governs removal or alteration of telegraph lines on property other than that of local authorities, establishing procedures for infrastructure modification when property circumstances change. The provision requires telegraph authorities to consider property owner interests while maintaining operational flexibility necessary for telecommunications network management.

Section 18 addresses tree removal procedures where vegetation interferes with telegraph communication, empowering Executive Magistrates to order tree removal upon telegraph authority application. The provision requires compensation for pre-existing trees while balancing operational requirements with property owner interests. This framework demonstrates early recognition of competing interests requiring judicial or administrative mediation.

Contemporary Legal Framework: Telecommunications Act 2023

Legislative Transformation and Modernization

The Telecommunications Act, 2023 represents transformative legislation designed to modernize India’s telecommunications regulatory framework while addressing technological evolution and infrastructure development challenges. This Act also strengthens the legal principles underlying telecommunications land policy in India by providing clear rules for land access and infrastructure deployment. The Act received Presidential assent on December 24, 2023, with phased implementation beginning June 26, 2024. The legislation aims to repeal the Indian Telegraph Act, 1885 and Indian Wireless Telegraphy Act, 1933, consolidating telecommunications regulation under contemporary legal standards.

Section 10 of the Telecommunications Act, 2023 expands the definition of “facility provider” beyond traditional licensees to include the Central Government, authorized entities, contractors, subcontractors, and agents working for government or authorized entities [2]. This broadened definition enables greater participation in telecommunications infrastructure development while maintaining regulatory oversight through licensing and registration requirements.

The Act establishes comprehensive frameworks for right-of-way access across public and private properties, recognizing telecommunications infrastructure as essential for national digital objectives. Section 11 grants facility providers rights to establish telecommunications networks on public property through prescribed procedures, while Section 12 addresses access to private property through consent-based mechanisms.

Right-of-Way Provisions Under the 2023 Act

Section 11 of the Telecommunications Act, 2023 empowers facility providers to establish telecommunications networks over public property upon obtaining appropriate permissions from relevant public entities. The provision establishes non-discriminatory and non-exclusive access principles, ensuring equitable treatment among telecommunications service providers while preventing monopolistic control over critical infrastructure corridors. These provisions form a key part of telecommunications land policy, guiding both public and private property access.

Section 12 addresses telecommunications network establishment over private property, requiring facility providers to obtain prior consent and enter mutual agreements with property owners. The provision balances infrastructure development requirements with property rights protection by mandating consensual arrangements rather than compulsory acquisition procedures. This approach reflects legislative recognition of private property sanctity while accommodating essential infrastructure development.

Section 15 establishes penalty frameworks for unauthorized telecommunications infrastructure installation, creating deterrent mechanisms against non-compliant development while ensuring regulatory enforcement capacity. The provision demonstrates legislative commitment to orderly infrastructure development through prescribed channels rather than ad hoc arrangements that might compromise property rights or public interests.

Telecommunications Right of Way Rules 2024

Regulatory Implementation Framework

The Telecommunications (Right of Way) Rules, 2024, notified on September 19, 2024, operationalize the statutory framework established by the Telecommunications Act, 2023. These rules supersede the Indian Telegraph Right of Way Rules, 2016 and Indian Telegraph (Infrastructure Safety) Rules, 2022, creating unified regulatory mechanisms for telecommunications infrastructure development. The rules address identified deficiencies in previous frameworks, including inconsistent charges by local bodies, varying permission timelines, and differential validity periods.

Rule 3 establishes comprehensive applicability to all telecommunications infrastructure requiring right-of-way access, whether on public or private property. The provision mandates use of designated online portals for all applications, ensuring standardization and transparency in permission processes. This digital-first approach facilitates efficient processing while creating audit trails for regulatory compliance and dispute resolution purposes.

Rule 4 requires every public entity to appoint nodal officers within thirty days of rule commencement, creating dedicated points of contact for telecommunications infrastructure coordination. Nodal officers serve as primary interfaces between public entities and facility providers, streamlining communication and reducing bureaucratic delays that previously hindered infrastructure development projects.

Public Property Access Procedures

Rule 6 establishes detailed procedures for facility providers seeking right-of-way over public property, requiring applications through the Gati Shakti Sanchar Portal accompanied by supporting documentation including authorization copies, network details, and impact mitigation measures. The standardized application process reduces administrative complexity while ensuring comprehensive information provision for informed decision-making by public entities.

Rule 7 mandates public entities to process underground telecommunications network applications within forty-five days, with automatic approval upon failure to decide within prescribed timeframes. This deemed approval mechanism prevents administrative delays while maintaining regulatory oversight through structured evaluation processes. The provision balances infrastructure development urgency with administrative due diligence requirements.

Rule 8 addresses overground telecommunications networks through similar portal-based applications, with provisions for utilizing public street furniture for small cell installations. The rule recognizes evolving telecommunications technology requiring distributed infrastructure deployment while ensuring efficient use of existing public assets. Compensation frameworks for street furniture usage provide revenue streams for public entities while facilitating network densification.

Private Property Access Framework

Rule 14 governs telecommunications network establishment over private property, requiring facility providers to obtain prior consent and formalize agreements with property owners. Unlike public property procedures, private property access depends entirely on consensual arrangements, reflecting constitutional property rights protection while accommodating essential infrastructure development needs.

The rule specifies mandatory agreement terms including entry methods, compensation provisions, damage restoration obligations, and safety measures. These standardized requirements ensure adequate protection for property owners while providing facility providers with clear operational parameters. Written formalization requirements create legal certainty for both parties while facilitating dispute resolution through documented terms.

Rule 15 addresses situations where facility providers cannot reach agreements with private property owners, establishing alternative mechanisms including government intervention where public interest justifies infrastructure development. However, the rule maintains property owner consent as the primary requirement, preserving constitutional property rights while recognizing exceptional circumstances requiring government involvement.

Tower Installation Policy and Procedures

Legal Framework for Mobile Tower Installation

Mobile tower installation operates within regulatory frameworks combining telecommunications law with local planning and environmental regulations, forming an essential component of telecommunications land policy. The Department of Telecommunications guidelines establish technical standards for tower installation while state and local authorities maintain jurisdiction over land use planning and building approvals. This multi-jurisdictional approach requires coordination among various regulatory bodies to ensure compliant tower installation.

Infrastructure Provider Category-I (IP-I) registration enables entities to establish and maintain telecommunications assets including towers, dark fiber, right-of-way, and duct space for leasing to licensed telecommunications service providers. IP-I providers operate under simplified regulatory frameworks without requiring traditional telecommunications licenses, facilitating private sector participation in infrastructure development while maintaining service quality through licensee oversight [3].

Tower installation procedures require compliance with radiation safety standards established by the Department of Telecommunications in coordination with health authorities. Safety Code 6 compliance ensures electromagnetic field exposure within prescribed limits while accommodating network coverage requirements. These technical standards balance public health protection with telecommunications service provision needs.

Property Owner Rights and Obligations

Property owners hosting mobile towers acquire contractual rights to rental income while accepting specific obligations regarding tower access and maintenance. Lease agreements typically specify rental rates, agreement duration, access rights for maintenance, and compensation for property damage. These contractual arrangements create mutual obligations balancing property owner interests with operational requirements for telecommunications service provision.

Property owners retain rights to compensation for tower installation and ongoing use, with rental rates varying based on location, tower specifications, and market conditions. Urban locations typically command higher rental rates reflecting land values and network traffic density. Rural installations may receive lower rental compensation but provide essential connectivity services to underserved areas.

Tower installation agreements must comply with local building codes, environmental regulations, and planning permissions. Property owners and telecommunications companies share responsibilities for obtaining necessary approvals while ensuring continued compliance with regulatory requirements. Non-compliance may result in installation removal or regulatory penalties affecting both parties to the agreement.

Regulatory Compliance and Safety Standards

Mobile tower installation requires compliance with multiple regulatory frameworks including telecommunications technical standards, building safety codes, environmental clearances, and local planning permissions. The Central Electricity Authority regulations govern power supply arrangements for tower operations while fire safety regulations address emergency access and equipment standards.

Electromagnetic field monitoring ensures ongoing compliance with radiation exposure limits established by health authorities. Regular testing and reporting requirements provide regulatory oversight while protecting public health concerns regarding tower operations. Non-compliance may result in operational restrictions or tower removal orders from relevant authorities.

Aviation clearance requirements apply to towers exceeding specified heights or located near airports and airfields. Civil aviation authorities assess potential interference with aircraft operations while considering telecommunications coverage requirements. These clearances ensure aviation safety while accommodating necessary telecommunications infrastructure development.

Fiber Network Rights and Infrastructure Development

Legal Framework for Fiber Infrastructure

Fiber optic cable deployment operates under telecommunications infrastructure frameworks established by the Telecommunications Act, 2023 and Right of Way Rules, 2024. Underground fiber infrastructure requires right-of-way permissions across public properties while aerial deployment may utilize existing utility infrastructure through sharing arrangements. The legal framework facilitates fiber deployment while protecting existing infrastructure and property rights.

Infrastructure Provider Category-I entities may establish and maintain dark fiber networks for leasing to telecommunications licensees, creating competitive infrastructure markets while maintaining service quality through licensee regulation. This framework enables infrastructure specialization while ensuring telecommunications service accountability through licensed operators responsible for end-user service provision.

Fiber network deployment requires coordination with multiple infrastructure authorities including road authorities, railway authorities, power utilities, and water supply entities where fiber routes cross or utilize existing infrastructure corridors. Inter-agency coordination mechanisms established under the rules facilitate efficient deployment while minimizing service disruptions to existing infrastructure users.

Underground Infrastructure Deployment

Underground fiber deployment requires detailed technical compliance with safety standards governing excavation, cable laying, and infrastructure restoration. The Right of Way Rules, 2024 establish technical specifications for underground telecommunications infrastructure including duct standards, manhole specifications, and cable protection requirements. These standards ensure infrastructure durability while facilitating future expansion and maintenance activities.

Public entities may require fiber network operators to utilize common duct infrastructure where available, promoting efficient use of underground space while reducing repeated excavation costs. Common duct requirements balance infrastructure efficiency with operator flexibility regarding network design and maintenance requirements. Shared infrastructure arrangements require coordination protocols ensuring service continuity for all users.

Restoration obligations require fiber network operators to restore affected areas to original conditions following installation activities. Performance guarantees and insurance requirements provide financial security for restoration obligations while ensuring quality workmanship in public area restoration. These requirements protect public infrastructure integrity while accommodating necessary telecommunications development.

Aerial Fiber Infrastructure

Aerial fiber deployment utilizes existing utility infrastructure including power lines, telephone poles, and dedicated telecommunications infrastructure. Sharing arrangements with utility providers require technical compatibility assessment and safety clearance procedures ensuring electromagnetic compatibility and physical safety requirements.

Power utility coordination addresses safety requirements for fiber cables installed on electrical infrastructure, including clearance distances, grounding procedures, and maintenance access protocols. These technical requirements ensure worker safety and service reliability while facilitating efficient infrastructure utilization through shared deployment arrangements.

Railway and highway authority coordination governs fiber deployment across transportation corridors, addressing safety clearances, maintenance access, and emergency response protocols. Transportation authority approval procedures ensure traffic safety while accommodating telecommunications infrastructure requirements for network connectivity across geographic barriers.

Regulatory Authorities and Enforcement Mechanisms

Department of Telecommunications Oversight

The Department of Telecommunications exercises primary regulatory authority over telecommunications infrastructure development through licensing, technical standards, and policy formulation. DOT coordinates with other government departments regarding infrastructure development while maintaining sector-specific expertise in telecommunications technology and market regulation. This centralized approach ensures consistent policy implementation while accommodating technological evolution and market dynamics.

DOT licensing authority encompasses telecommunications service providers, infrastructure providers, and equipment manufacturers, creating comprehensive regulatory oversight across the telecommunications value chain. License conditions specify infrastructure development obligations, service quality requirements, and consumer protection measures while providing operational flexibility for technology innovation and market competition.

Technical standards development by DOT establishes equipment specifications, safety requirements, and operational procedures governing telecommunications infrastructure. These standards ensure interoperability, safety, and service quality while accommodating technological advancement and international compatibility requirements. Regular updates reflect technological evolution while maintaining infrastructure reliability and safety standards.

State and Local Authority Coordination

State governments exercise concurrent jurisdiction over telecommunications infrastructure through land use planning, building approvals, and environmental clearances, ensuring alignment with telecommunications land policy objectives. State-level coordination mechanisms established under the Right of Way Rules facilitate efficient approvals while respecting state autonomy over local planning decisions. This federal-state coordination balances national telecommunications objectives with local planning priorities.

Local authorities maintain jurisdiction over building permits, road cutting permissions, and utility coordination within their territorial limits. Municipal coordination requirements ensure telecommunications infrastructure development complies with local planning objectives while minimizing disruption to existing infrastructure and community activities. Local authority cooperation facilitates efficient infrastructure deployment while addressing community concerns regarding telecommunications development.

Environmental clearance authorities assess telecommunications infrastructure impacts on ecological systems, cultural heritage sites, and community environments. Environmental impact assessment procedures ensure sustainable development practices while accommodating necessary infrastructure development for telecommunications service provision. These assessments balance environmental protection with infrastructure development requirements.

Dispute Resolution Mechanisms

The Telecommunications Act, 2023 establishes dispute resolution mechanisms through telecommunications tribunals and appropriate commissions for conflicts arising from infrastructure development activities. These specialized forums provide expert adjudication regarding technical and commercial disputes while ensuring efficient resolution of conflicts that might otherwise delay infrastructure development projects.

Civil courts retain jurisdiction over property disputes and contractual conflicts arising from telecommunications infrastructure development, particularly regarding private property access and compensation issues. Court procedures provide comprehensive legal remedies while accommodating the technical complexity of telecommunications infrastructure disputes through expert testimony and technical assessment.

Alternative dispute resolution mechanisms including arbitration and mediation provide efficient resolution options for commercial disputes between telecommunications entities and property owners. These mechanisms reduce litigation costs while providing flexible resolution procedures accommodating the technical and commercial complexity of telecommunications infrastructure relationships.

Recent Judicial Developments and Case Law 

Supreme Court Guidance on Telecommunications Infrastructure

Recent Supreme Court pronouncements have clarified the relationship between telecommunications infrastructure development and property rights protection. The Court’s recommendations for statutory appeal mechanisms regarding compensation under the Indian Telegraph Act, 1885 reflect judicial recognition of the need for structured dispute resolution in telecommunications infrastructure development. These recommendations emphasize the importance of adequate compensation mechanisms while ensuring infrastructure development efficiency.

The Supreme Court’s emphasis on constitutional property rights protection under Article 300A requires telecommunications infrastructure development to comply with due process requirements including adequate notice, fair compensation, and judicial review opportunities. These constitutional principles apply to telecommunications infrastructure development while recognizing the public utility nature of telecommunications services justifying reasonable property access requirements.

Recent judicial interpretations have distinguished between temporary access for telecommunications infrastructure and permanent land acquisition, clarifying that telecommunications infrastructure typically requires easement rights rather than ownership transfer. This distinction reduces property owner concerns while providing telecommunications operators with necessary access rights for infrastructure development and maintenance activities.

High Court Decisions on Infrastructure Development

Various High Courts have addressed conflicts between telecommunications infrastructure development and local planning regulations, generally favoring telecommunications development where proper regulatory approvals have been obtained. These decisions emphasize the national importance of telecommunications infrastructure while requiring compliance with applicable regulatory frameworks including environmental and safety standards.

High Court decisions regarding electromagnetic field safety have consistently supported telecommunications infrastructure development where operators comply with prescribed safety standards established by health authorities. These decisions balance public health concerns with telecommunications service requirements while emphasizing the importance of regulatory compliance in addressing community concerns regarding tower installation.

Property rights decisions by High Courts have emphasized the contractual nature of telecommunications infrastructure arrangements with private property owners, requiring clear agreement terms and fair compensation mechanisms. These decisions protect property owner interests while recognizing the essential nature of telecommunications infrastructure for economic and social development objectives.

Economic and Social Implications

Infrastructure Investment and Economic Development

Telecommunications infrastructure development represents substantial private sector investment in essential public infrastructure, creating economic benefits through improved connectivity, business development opportunities, and employment generation. The legal framework’s facilitation of private infrastructure investment reduces government financial burdens while ensuring adequate infrastructure development for national digital objectives.

Property owners hosting telecommunications infrastructure benefit from rental income streams while communities gain improved telecommunications services supporting economic development and social connectivity. These mutual benefits justify regulatory frameworks facilitating infrastructure development while ensuring fair compensation and community benefit sharing from telecommunications infrastructure deployment.

Rural telecommunications infrastructure development receives particular policy attention due to market failure in commercially unviable areas requiring government intervention or subsidy mechanisms. The Universal Service Obligation Fund provides financial support for rural infrastructure development while maintaining private sector efficiency in infrastructure deployment and operation.

Digital Inclusion and Social Development

Telecommunications infrastructure development directly supports digital inclusion objectives by extending connectivity to underserved communities and enabling access to digital services including education, healthcare, and government services. The legal framework’s facilitation of efficient infrastructure deployment supports social development objectives while balancing property rights and community interests.

Fiber network expansion enables high-speed internet access essential for modern economic activities including digital commerce, remote work capabilities, and access to online education and healthcare services. The regulatory framework’s support for fiber infrastructure development facilitates India’s digital transformation while ensuring equitable access across geographic and economic demographics.

Mobile tower deployment enables widespread cellular connectivity supporting voice communication and mobile internet access essential for social and economic participation in contemporary society. The regulatory framework balances rapid deployment requirements with community concerns regarding aesthetics, safety, and property values while ensuring adequate compensation for property use.

Future Outlook and Emerging Challenges

Technological Evolution and Regulatory Adaptation

Fifth-generation cellular technology deployment requires dense network infrastructure with reduced cell sizes and increased site requirements, creating new challenges for site acquisition and regulatory approval processes. The regulatory framework must adapt to accommodate 5G technical requirements while maintaining property rights protection and community engagement procedures established for traditional telecommunications infrastructure.

Small cell deployment for 5G networks requires access to numerous low-power sites including street furniture, building facades, and utility infrastructure, creating new regulatory challenges regarding permitting procedures and compensation mechanisms. The Right of Way Rules, 2024 address small cell deployment through streamlined procedures while ensuring adequate property owner protection and compensation arrangements.

Internet of Things applications and edge computing requirements create demand for distributed telecommunications infrastructure requiring flexible access arrangements and rapid deployment capabilities. The regulatory framework must accommodate these technological developments while maintaining safety standards and property rights protection appropriate for evolving telecommunications infrastructure requirements.

Sustainability and Environmental Considerations

Environmental sustainability considerations increasingly influence telecommunications infrastructure development through energy efficiency requirements, renewable energy integration, and minimal environmental impact deployment methods. The regulatory framework must balance environmental protection objectives with infrastructure development requirements while accommodating technological solutions reducing environmental impacts.

Circular economy principles applied to telecommunications infrastructure emphasize equipment reuse, recycling capabilities, and sustainable material usage in infrastructure development. Regulatory frameworks may evolve to incorporate sustainability requirements while maintaining infrastructure development efficiency and cost-effectiveness for telecommunications service provision.

Climate change adaptation requirements may necessitate infrastructure resilience standards addressing extreme weather events, sea level rise, and temperature variations affecting telecommunications equipment operation. The regulatory framework must anticipate these challenges while ensuring infrastructure reliability and service continuity under changing environmental conditions.

Conclusion

India’s telecommunications land policy represents a sophisticated balance between infrastructure development imperatives and property rights protection, evolved through legislative reform from colonial-era statutes to contemporary digital infrastructure requirements. The Telecommunications Act, 2023 and Right of Way Rules, 2024 establish modernized frameworks facilitating efficient infrastructure deployment while ensuring adequate compensation and community protection mechanisms.

The legal framework’s emphasis on consensual arrangements for private property access demonstrates respect for constitutional property rights while providing alternative mechanisms where public interest justifies infrastructure development. This balanced approach supports telecommunications infrastructure expansion necessary for digital transformation objectives while maintaining property owner confidence in legal protection mechanisms.

Current challenges in telecommunications infrastructure development reflect broader tensions between rapid technological evolution and established legal frameworks requiring periodic adaptation to accommodate emerging technologies and deployment methods. The regulatory framework’s flexibility mechanisms enable adaptation while maintaining core principles of property rights protection and public interest service provision.

Future success in telecommunications land policy implementation depends on continued coordination between federal telecommunications regulation and state and local planning authority, ensuring infrastructure development efficiency while respecting local community interests and environmental protection requirements. The framework’s emphasis on stakeholder consultation and dispute resolution mechanisms provides foundations for addressing emerging challenges while maintaining telecommunications infrastructure development momentum essential for India’s digital economy objectives.

The evolving telecommunications land policy requires continued legal framework refinement to address technological innovation, environmental sustainability, and social equity considerations while preserving the fundamental balance between infrastructure development and property rights protection that characterizes India’s telecommunications land policy architecture.

References

[1] Centre for Internet and Society. (n.d.). Indian Telegraph Act, 1885. 

[2] S&R Associates. (2025). Fiber Opportunity in India: Regulatory Framework and Right-of-Way Management. Retrieved from https://www.snrlaw.in/fiber-opportunity-in-india-regulatory-framework-and-right-of-way-management/ 

[3] Department of Telecommunications. (n.d.). Infrastructure Provider. 

[4] Lexology. (2024). Telecommunication Right of Way Rules, 2024. Retrieved from https://www.lexology.com/library/detail.aspx?g=17620e29-7288-4030-b190-b8c32722f229 

[5] JSA Law. (2024). Telecommunication Right of Way Rules, 2024. Retrieved from https://www.jsalaw.com/newsletters-and-updates/telecommunication-right-of-way-rules-2024/ 

[6] Savemax. (2025). Rules and Implications of Mobile Tower Installation 2024. Retrieved from https://savemax.in/blogs/mobile-tower-installation-on-property-pros-cons/ 

[7] Lexology. (2024). Telecommunications Act, 2023 – An Overview of Key Changes and their Impact. Retrieved from https://www.lexology.com/library/detail.aspx?g=3454b65d-0f2d-4c0e-88f7-1a84535abbf2 

[8] TaxGuru. (2024). Draft Telecommunications (Right of Way) Rules, 2024. Retrieved from https://taxguru.in/corporate-law/draft-telecommunications-right-wayrules2024.html