INTRODUCTION
Technology has become a part of our day-to-day activity. Whether it is transportation, banking, or shopping or even doing our domestic chores, technology is an inevitable part of it, especially information technology. Many processes of our business as well as private life is dependent on its use because we gain advantageous information as a result of it.
Health sector is not an exception to this for it is necessary to introduce a new kind of creation, storage and circulation of information that would serve needs of every person who is involved in health care (needs of medical practitioner or hospital or other healthcare professionals or healthcare recipient i.e., patient).1
The World Health Organization (WHO) defines Telemedicine as, “The delivery of healthcare services, where distance is a critical factor, by all healthcare professionals using information and communication technologies for the exchange of valid information for diagnosis, treatment and prevention of disease and injuries, research and evaluation and for the continuing education of healthcare providers, all in the interests of advancing the health of individuals and their communities.”2 In simple words, telemedicine is the use of electronic information and communications technologies to provide and support health care when distance separates the participants.3
According to the Centers for Medicare and Medicaid Services (CMS), telemedicine is ‘a service that seeks to improve a patient’s health by permitting two- way, real-time interactive communication between the patient and the physician at a distant site.’
The National Medical Council (NMC) of India has defined tele-medicine as ‘the delivery of health care services, where distance is a critical factor, by all health care professionals using information and communication technologies for the exchange of valid information for diagnosis, treatment and prevention of disease and injuries, research and evaluation, and for the continuing education of health care providers, all in the interests of advancing the health of individuals and their communities.’
CONCEPT OF TELEMEDICINE
Many experts use the terms ‘tele-health’ and ‘tele-medicine’ interchangeably. However, it must be noted that tele-health refers to the ‘use of telecommunications and information technology to access health care services remotely and manage your health care.4 Telehealth is similar to telemedicine but includes a wider variety of remote healthcare services beyond the doctor-patient relationship. It often involves services provided by nurses, pharmacists or social workers, for example, who help with patient health education, social support and medication adherence, and troubleshooting health issues for patients and their caregivers.5
It is essential to also note that telemedicine has its own pros and cons. On one hand, it has provided greater access to quality healthcare for persons living in remote areas and people in lower socio-economic strata of the society, while on the other hand fear of reduced inter-personnel relationship between the doctor and patient exists. Secondly, it is cost-effective and saves time of the patients, however, there is an underlying risk of hacking and misuse of data collected. Besides being a convenient way of consultation from the comfort of one’s home, one needs to be familiar with the use of technology, which poses a challenge for senior citizens.
HISTORY OF TELEMEDICINE
The origin and growth of telemedicine are deeply rooted in the evolution of communication technologies and the continuing need to deliver healthcare across distances. Even before the mid-20th century, medical communication via telephones and radiotelegraphy laid the groundwork for remote diagnosis and consultation. Early in the 1900s, clinicians used telephone and wireless technology to communicate vital health information, reflecting an emerging recognition of telecommunications’ potential in healthcare delivery.6 By the 1940s, radiographic images were transmitted by telephone between towns in Pennsylvania, representing some of the first documented electronic medical data transfers.7
The 1950s witnessed more developed applications, notably in teleradiology, where radiologic images were shared between health centres, improving remote diagnostics in areas without specialised services. This period also saw pioneering uses of two-way interactive television for medical education and remote neurological examinations, further pushing the boundaries of telemedicine.8 In the United States, the University of Nebraska created a two-way interactive television link in 1959, enabling clinical communication and instruction across significant distances, and by the mid-1960s expanded such links with rural hospitals.9
The National Aeronautics and Space Administration (NASA) played a major role in shaping telemedicine as it is known today. Beginning with efforts in the 1960s to monitor astronaut health, NASA developed physiologic remote monitoring systems during the Mercury space programme, demonstrating that vital signs could be transmitted and interpreted over long distances, even from space.10 This technology laid the foundation for later applications of remote patient monitoring on Earth and highlighted the feasibility of real-time telemedical interactions in extreme environments.
Subsequent decades saw steady advances propelled by improvements in information and communication technologies. The advent of the internet in the 1990s revolutionised telemedicine by enabling more efficient transmission of medical images, real-time video interactions, and the ability to share vital sign data across vast distances.11 These technological advances transformed telemedicine from isolated experimental programmes into widely applicable healthcare delivery tools.
Today, the accessibility and affordability of mobile and digital technologies have greatly expanded telemedicine’s reach. Contemporary telemedicine encompasses a wide range of services, including video consultations, remote monitoring, store-and-forward telehealth, and integration with electronic health records, underscoring the foundational role that communication technologies have played in its historical evolution.12
INDIAN TELEMEDICINE BEFORE THE OUTBREAK OF COVID-19
In India, telemedicine made a modest beginning in 2001 with a Telemedicine Pilot Project in 2001, linking Chennai’s Apollo Hospital with the Apollo Rural Hospital at Aragonda village in the Chittoor district with help of ISRO (Indian Space Research Organization). A few other noteworthy examples of the successfully established Indian telemedicine services include mammography services at Sri Ganga Ram Hospital, Delhi; oncology at Regional Cancer Centre, Trivandrum; surgical services at Sanjay Gandhi Postgraduate Institute of Medical Sciences, School of Telemedicine and Biomedical Informatics, and many more.
In an attempt to coalesce the available public health data and provide easy access, the Ministry of Health under the Government of India has taken up projects like Integrated Disease Surveillance Project (IDSP), National Cancer Network (ONCONET), National Rural Telemedicine Network, National Medical College Network and the Digital Medical Library Network.
Setting up of standardized telemedicine practice guidelines by the Department of Information Technology in the Government of India, and setting up of a National Telemedicine Task Force by the Health Ministry, in 2005, were some of the other positive steps taken by the government. International projects like the Pan-African e-Network Project, and the SAARC (South Asian Association for Regional Co-operation) Telemedicine Network projects have also been taken up as an initiative of the External Affairs Ministry, strategically placing Indian telemedicine in the global scenario13.
Telemedicine is one field which was successful in invoking a keen interest in the private sector and making them take an active part in public health management. Some of the current major Indian private sector players in telemedicine include Narayana Hrudayalaya, Apollo Telemedicine Enterprises, Asia Heart Foundation, Escorts Heart Institute, Amrita Institute of Medical Sciences and Aravind Eye Care. They function with support from the central and state governments and from organizations like ISRO who guide them with appropriate and updated technology.
Telemedicine division of Ministry of Health and Family Welfare (MoHFW), the central government has set up a National Telemedicine Portal for implementing a green field project on e-health establishing a National Medical College Network (NMCN) for interlinking the Medical Colleges across the country with the purpose of e-Education and a National Rural telemedicine Network for e-Healthcare delivery. As a constituent of the e-health wing of the National Health Portal (NHP), National Digital Health Authority of India (NDHAI) or National e-health authority (NeHA) is being set up with a vision of achieving high quality health services for all Indians through the cost-effective and secure use of ICTs in health and health-related fields. It will also ensure safe data transmission during telemedicine practices.
The National Rural AYUSH Telemedicine Network aims to promote the benefit of traditional methods of healing to a larger population through telemedicine. Village Resource Centre (VRC) concept has been developed by ISRO to provide a variety of services such as tele-education, telemedicine, online-decision support, interactive farmers’ advisory services, tele-fishery, e-governance services, weather services and water management. The VRCs not only act as learning centres and but also provide connectivity to specialty hospitals, thus bringing the services of expert doctors to the villages. Nearly 500 such VRCs have been established in the country.
AROGYASREE is another internet-based mobile telemedicine conglomerate that integrates multiple hospitals, mobile medical specialists and rural mobile units/clinics. The project is an initiative of Indian Council of Medical Research (ICMR). They have collaborated with a team of scientists from University of Karlsruhe, Germany who are working on the design of an ECG jacket which can be used for the continuous monitoring of a patient’s ECG without hospitalization.
ITS INCREASING DEMAND DURING THE PANDEMIC
A. The United States of America (USA)
Before March 2020, telemedicine use in the United States was on a steadily increasing trajectory, but its absolute integration remained low, and the logistics were complex.14 Despite certain difficulties 76% of US hospital systems used some form of telemedicine as of 2018, with radiology, psychiatry, and cardiology noted as the highest users of the modality.15 In a systematic review on the topic, the most frequently cited factors associated with patient telehealth satisfaction included improved outcomes (defined a variety of ways owing to heterogeneity of the 44 included studies), preferred modality over face-to-face visits, ease of use, low cost, improved communication, and elimination of travel time.16 Patients also expressed some concerns about telemedicine, such as data security.17
The widespread recognition of COVID-19 resulted in removal of prior barriers that existed in telemedicine. As patients who would have had in-person office visits were either in quarantine or fearful of going out of their house, a great need to expand the use of telemedicine was felt. Thus, in early March 2020 alterations to the Medicare facilities were made by the Congress that allowed telemedicine services to flourish.
B. India
As per a news article of the Business Line by The Hindu, Tattvan E-clinics, a telemedicine healthcare clinic, had released some insights about how far tele-medical consultation has been adopted. One of the reasons for its growth was the fact that people were forced to stay at home and had to cancel traditional medical appointments. Though barriers like education, innovations, language, etc. made consultation complicated at the initial stage, around 70% agreed that such consultations will be the new normal in India.18
Practo (a mobile application that provides video consultation with doctors) reported that five crore Indians accessed healthcare services online during the first phase of lockdown between March 2020 to May 2020. Also, Ministry of Health and Family Welfare in partnership with NITI Aayog released ‘Telemedicine Practice Guidelines’ on 25th of March, 2020. As per the said guidelines, patients could consult with a registered medical practitioner (RMP) for diagnosis and treatment of their condition or for health education and counseling. A patient could also use telemedicine service for follow-up consultation on their ongoing treatment with the same RMP who had prescribed the treatment in an earlier in-person consult.19
C. Other countries
According to an OECD Survey on Telemedicine and COVID-19, before March 2020, nine countries allowed medical consultations to be performed only in the physical presence of the patient. During the pandemic, eight countries (Belgium, Czech Republic, England, Estonia, Hungary, Korea, Latvia and Luxembourg) began paying for teleconsultations through government or compulsory schemes, whereas eight countries (Belgium, England, Estonia, Germany, Hungary, Ireland, Latvia and Switzerland) began paying for remote patient monitoring services through government or compulsory schemes.20
CURRENT SCENARIO POST COVID-19 AMID DATA CONCERNS
The government of India introduced its telemedicine service, e-Sanjeevani, as part of its ‘Digital India’ initiative in August 2020. During the COVID-19 pandemic, practitioners used video conferencing to diagnose and treat patients in geographically diverse locations. The platform currently permits two types of telemedicine services that is Doctor to Doctor (e-Sanjeevani) and Patient-to- Doctor (e-Sanjeevani OPD). India has relied on this model for providing non-COVID-19 essential healthcare, with approximately 3 million consultations on the e-Sanjeevani platform as on 17th of March, 2021.
Following the COVID-19 pandemic in India, a new policy has been adopted and extended to connect larger hospitals to smaller health centres in remote areas. As it expands, medical college hospitals and large government hospitals in the states would act as ‘hubs’ to provide tele-consultation services to ‘spokes’, or primary health care centres (a “hub and spoke” model).
A. Regulation of Practise of Telemedicine in India
In India, the telemedicine services come under the jurisdiction of Ministry of Health and Family Welfare and the Department of Information Technology. Prior to 2020, there were no guidelines to regulate the practice of telemedicine in India. In 2018, the Bombay high court, in Deepa Sanjeev Pawaskar & Another v. State of Maharashtra, refused to grant anticipatory bail to two doctors involved in the treatment of a patient and questioned the legitimacy of medicines prescribed over telephone. The Court held that Dr. Deepa had prescribed medicines without arriving at a diagnosis which amounts to a case of culpable negligence. This judgment was overruled by the Hon’ble Supreme Court. This judgment led to medical bodies petitioning the Medical Council of India (now the National Medical Commission) and the government to prepare and issue guidelines for the practice of telemedicine in the country.
Prior to the Deepa Sanjeev Pawaskar case, the Hon’ble Supreme Court, in the case of Martin J.F. D’Souza v. Mohd. Ishfaq had observed that the prescription should not ordinarily be given to a patient without actual physical examination. In addition, they observed that the tendency to give prescription over the telephone should be avoided, except in cases of emergency.21
On 25 March 2020, the Ministry of Health and Family Welfare, Government of India, in partnership with the NITI Aayog, issued the Telemedicine Practice Guidelines, 2020 under the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations. The primary objective of these guidelines is to provide practical guidance to registered medical practitioners to enable the effective integration of telemedicine into routine clinical practice, while ensuring safe, ethical, and legally compliant delivery of healthcare services. The guidelines seek to facilitate access to healthcare, optimise the use of available health resources, and protect the interests and safety of both patients and medical practitioners.22
The telemedicine practice guidelines make it clear that both the registered medical practitioner (RMP) and the telemedicine service provider are required to comply with various laws related to practice of medicine in India, together with laws governing information technology, such as:
1. Drugs and Cosmetics Act, 1940, and Drugs and Cosmetic Rules, 1945,
2. The Narcotic Drugs and Psychotropic Substances, Act,
3. The Indian Medical Council Act, 1956 and Indian Medical Council Regulations, 2002,
4. The Clinical Establishment (Registration and Regulation) Act, 2010,
5. The Information Technology Act, 2000 (IT Act),
6. The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, and
7. The Information Technology (Intermediary Guidelines) Rules, 2011.
B. Ethical and Legal Issues associated with Telemedicine in India
In a developing country like ours, there are several legal and ethical challenges related to application and growth of telemedicine with a background of inadequate health infrastructure. Some of these challenges are as follows:
1. Doctor-Patient relationship
A good patient-doctor relationship is the most essential requirement of medical practice. It helps in understanding patients’ health problem, builds confidence and compliance with treatment and overall satisfaction. However, there are several challenges in a telemedicine practice, such as lack of face-to-face interaction, absence of physical examination, and consultation with multiple physicians. These factors may lead to trust-deficit between a doctor and a patient. There are also additional risks associated with telemedicine like the use of inappropriate language, improper behaviour as well as violation of boundaries of a professional relationship.
The IT Act 2000, does not directly cover the practice of medicine using ICT. The use of digital signature, preservation of electronic records, their ownership, recognition and delivery have been made legal. It is possible that doctor-patient relationship might come under legal purview under the aforementioned factors.
2. Informed consent
Consent is the expression of right to autonomy, it gives an individual the freedom to make a conscious and voluntary decision to engage in activity or process. It is important that the consent of the patient should always be an informed consent so as to protect their interests. The key elements of informed consent are voluntary disclosure of information, patient understanding and authorization. Informed consent is an important medicolegal requirement for all doctor-patient relationship and failure to do so is a tort or crime. Therefore, it is essential that informed consent be taken for all medical interactions whether in-person or through telemedicine. Informed consent in telemedicine is mandatory in several countries like United Kingdom, France, Malaysia and South Africa.
In Indian context, informed consent is one of the essential requirements of the Data Protection Rules. The Digital Personal Data Protection Bill (2022) allows the processing of data for lawful purposes. It also mandates that that the contact details of the data protection officer be provided as a resource and the data provider reserves the right to use of the data provided.
3. Privacy and health data Protection
Maintenance of confidentiality, privacy and data protection is a major challenge in the application and use of telemedicine as security breaches are a constant threat. The terms ‘privacy’ and ‘confidentiality’ are at times used interchangeably however, there is a difference between the two.
The definition of the word ‘privacy’ incorporates individuals or groups determining for themselves, when, how and to what extent the private information about themselves can be shared or communicated with others. Confidentiality is relational and always includes two persons, and occurs when one discloses private information to other with an understanding that the same will remain confidential for example, a doctor-patient relationship in this case. In medical practice (either face-to-face or digital healthcare) there are two types of privacy:
(a) informational privacy and
(b) decisional privacy.
Informational privacy relates to maintaining of data protection and security whereas decisional privacy denotes autonomy in health-related decision-making. Hippocratic Oath and International Code of Medical ethics have made the right to privacy an integral part of medical ethics. It mandates that every medical practitioner must maintain privacy of the patient and confidentiality of the information provided even after the death of the patient.
In India the ‘the right to privacy’ has been intensely debated in the judicial realm. In 2017, the Hon’ble Supreme Court in the landmark nine-judgement of K.S. Puttaswamy v. Union of India ruled that the right of privacy is a fundamental right and that privacy is intrinsic to life with dignity. It also ruled that informational privacy is an integral part of right to privacy. This implies that data protection is covered by the right to privacy and any government regulations covering data protection must balance between the right to privacy and legitimate concerns of the state.
There is a potential risk of leakage of patient-related personal information due to security breaches in telecommunication system during practice of telemedicine. The onus of responsibility for safeguarding the information obtained during telemedicine consultation thus lies with the medical practitioner. The practice of telemedicine is complex as it is a integration of medical practice with information technology and there are no special laws pertaining to telemedicine in the country.
Telemedicine in India is regulated by existing medical and information technology legislations as mentioned earlier in this article. The IT Act of 2000 and Data Protection Rules of 2011 are not specific to healthcare data protection and it provides only a basic level of data protection by mandating that the data owner be informed about the manner of use of data. The Personal Data Protection Bill tabled by government in the Lok Sabha in 2019 was withdrawn in 2022. Now in place of a single comprehensive law the government has proposed to have four new laws tackling social media, digital technology, telecommunications, and privacy.
4. Malpractice and liability
Once the doctor-patient relationship is established, it is the duty of the doctor to offer the standard of care as per the existing guidelines and practices. Any breach of telemedicine act is considered as misconduct and appropriate action is taken. Liabilities under the law may also arise as liability in civil negligence, liability in criminal negligence, liability under the Consumer Protection Act of 1986 along with vicarious liability.
LATEST TRENDS IN TELEMEDICINE (2024–2026): POST-COVID CONSOLIDA-TION AND NEW PRIVACY RISKS
A. Telemedicine is shifting from “pandemic substitute” to “hybrid care default”
Post-COVID, telemedicine is no longer treated as a temporary emergency tool. Instead, health-
care systems are increasingly adopting hybrid care models, where triage, follow-ups, chronic disease management, and counselling are delivered remotely, while physical examination and procedures remain in-person. This shift is driven by patient preference for convenience and by health systems trying to reduce OPD load and improve continuity of care.23
B. India: eSanjeevani at scale and deeper integration with ABDM (ABHA and digital health records)
India’s public telemedicine programme, eSanjeevani, has moved into a high-volume service delivery phase and is increasingly positioned as a backbone for remote consultations across states.24 In parallel, India’s Ayushman Bharat Digital Mission (ABDM) is expanding core digital infrastructure through ABHA (digital health IDs), health facility and professional registries, and linkage of health records, which strengthens interoperability and continuity for teleconsultations.25 Importantly, eSanjeevani services are also being aligned with the ABDM ecosystem, enabling ABHA-based access and record linkage in practice.26
C. India: DPDP Rules, 2025 and the “compliance era” for telemedicine platforms
A major recent development affecting telemedicine is the operationalisation of India’s Digital Personal Data Protection (DPDP) framework through DPDP Rules, 2025.⁵ With rules now notified, telemedicine platforms and hospitals processing patient data face heightened compliance expectations regarding lawful processing, notice, consent architecture, and governance.27 A particularly important forward-looking element is the evolving structure around consent management, which is likely to become central for digital health ecosystems where multiple actors (platforms, labs, pharmacies, insurers) may handle patient data across a care journey.28
D. Rising cybersecurity and “data exposure” anxieties in the telehealth ecosystem
As telemedicine expands, attack surface expands. Patient data flows across apps, video platforms, cloud storage, e-pharmacies, diagnostic portals, and messaging tools, increasing the risk of unauthorized disclosure. Recent government attention to unlawful exposure of citizens’ personal data (including directives relating to access-blocking for data-leak sites) reflects a growing policy focus on digital privacy enforcement.29 In healthcare, such exposures are more harmful because medical information can cause stigma, discrimination, and long-term reputational injury.
E. Global trend: remote monitoring + chronic care financing and the next phase of telehealth regulation
Internationally, telehealth growth is increasingly tied to remote patient monitoring (RPM) and chronic care pathways, rather than one-off video consultations. New payment experiments and policy reforms (especially in the U.S.) show that governments and insurers are testing models that pay for outcomes and chronic disease management supported by digital tools, which may further normalize telehealth as routine care infrastructure.30
SUGGESTIONS
The Telemedicine Practice Guidelines (TGP) 2020 is restricted to only medical professionals registered under the MCI Act (now the NMC). It excludes other health professionals like dentists, AYUSH doctors, nurses and paramedical staff. To ensure that all aspects of healthcare are taken into account following are a few suggestions:
(i) The TPG must be modified to include health professionals rather than RMP as its definition includes dentist, nurses, clinical psychologists and even AYUSH doctors.
(ii) Defining the area of healthcare service to be provided by each of these enumerated health professionals.
(iii) Regulation of tele-ICU, tele-nursing, tele-radiology, which are all part of telemedicine umbrella.
(iv) Restriction on providing care over platform who are not equipped to ensure patient privacy.
(v) Definition and division of liability in the event of harm is caused to the patient during or due to a teleconsultation.
(vi) Regulation of Artificial Intelligence (AI) and machine learning (ML) platforms as the TPG is not applicable to it currently.
The TPG also does not contain adequate guidance on obtaining informed consent besides as to how to use the obtained data of the patient. The TPG considers that the consent of patient is implied once the patient initiates telemedicine and the RMP explains the process and obtains the consent. However, the patient is usually not informed about the limits of telemedicine consultation prior to the commencement of consultation nor is he informed regarding how the data they provide may be used. Thus, the patient should be provided an option to take a print copy detailing the limits of telemedicine consultation and safeguards for privacy.
In addition to the above recommendations, the definition of follow-up consultation should be modified to include first consultation by another RMP in its ambit. The TPG should also modify the age limit wherein children above the age of 14 should be permitted to take telemedicine consultation independently on issues related to mental health, reproductive issues and wellness. However, even for these issues parents/guardians would be required to give their consent for telemedicine consultation and to the privacy policy.
Confidentiality privacy, malpractice, negligence are major issues related to practice of telemedicine and presently, the IT Act of 2000 as amended in 2008, covers issues only related to confidentiality and privacy under Sections 63 to 74 wherein breach of confidentiality and privacy as an offence is very limited in its scope under Section 72. The punishment laid out is imprisonment only up to 2 years or a fine up to 2 years or both. Secondly, there may be breach of contractual obligation which attracts merely a civil suit.
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Footnotes
1. Agnese Gusarova, Data Protection in Telemedicine, ResearchGate (2011), available at https://www.researchgate.net/publication/278116564_Data_Protection_in_Telemedicine (last visited 15 Dec. 2025).
2. Field Marilyn J. & Institute of Medicine (US) Committee on Evaluating Clinical Applications of Telemedicine, Telemedicine: A Guide to Assessing Telecommunications in Health Care (National Academies Press, Washington DC, 1996), available at https://www.ncbi.nlm.nih.gov/books/NBK45440/ (last visited 15 Dec. 2025).
3. Rainer Vetter, Aspects of Data Protection in Telemedicine, 1 (2001), available at National Center for Biotechnology Information (NCBI), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2782224/ (last visited 15 Dec. 2025).
4. Mayo Clinic Staff, Telehealth: Technology Meets Health Care, Mayo Clinic, available at https://www.mayoclinic.org/healthy-lifestyle/consumer-health/in-depth/telehealth/art-20044878 (last visited 15 Dec. 2025).
5. Federal Communications Commission (FCC), Telehealth, Telemedicine, and Telecare: What’s What?, FCC (United States), available at https://www.fcc.gov/general/telehealth-telemedicine-and-telecare-whats-what (last visited 15 Dec. 2025).
6. Telehealth Resource Center, History of Telehealth and Telemedicine (noting early use of telephones and radiotelegraphy in medicine), available at https://telehealthresourcecenter.org/wp-content/uploads/2021/11/History_of_Telehealth.pdf (last visited Dec. 15, 2025).
7. CCJM, Telemedicine: Past, Present, and Future (describing radiograph transmission in the 1940s), 85 Cleveland Clinic Journal of Medicine 938 (2018).
8. SightCall, History of Telemedicine (noting teleradiology and early video use), available at https://sightcall.com/blog/history-telemedicine (last visited Dec. 15, 2025).
9. Eagle Telemedicine, The History of Telemedicine (detailing University of Nebraska interactive TV use), available at https://www.eagletelemedicine.com/telemedicine-101/the-history-of-telemedicine-to-mainstream-today/ (last visited Dec. 15, 2025).
10. NASA, A Brief History of NASA’s Contributions to Telemedicine (describing early space medical monitoring systems), available at https://www.nasa.gov/wp-content/uploads/2024/03/nasatelemedicine-briefhistory.pdf (last visited Dec. 15, 2025).
11. NCBI Bookshelf, Introduction and Background – Telemedicine, in Telemedicine: A Guide to Assessing Telecommunications in Health Care (1996) (discussing impact of telecommunication tech on telemedicine), available at https://www.ncbi.nlm.nih.gov/books/NBK45440/ (last visited Dec. 15, 2025).
12. OECD, The Role of Digital Health Technologies in Healthcare Delivery (noting modern digital telemedicine services), OECD Policy Brief (2024).
13. Ministry of Health and Family Welfare, Government of India, National Health Information and Telemedicine Programmes (MoHFW, New Delhi, 2015).
14. Weigel G., Ramaswamy A., May 11 M.F.P. Opportunities and Barriers for Telemedicine in the U.S. During the COVID-19 Emergency and Beyond. KFF. Published May 11, 2020. 2020. https://www.kff.org/womens-health-policy/issue-brief/opportunities-and-barriers-for-telemedicine-in-the-u-s-during-the-covid-19-emergency-and-beyond/ Available at: Accessed December 21, 2021.
15. Kane C.K., Gillis K. The Use Of Telemedicine By Physicians: Still The Exception Rather Than The Rule. Health Aff (Millwood) 2018;37(12):1923–1930.
16. Kruse C.S., Krowski N., Rodriguez B., et al. Telehealth and patient satisfaction: a systematic review and narrative analysis. BMJ Open. 2017.
17. Haluza D., Naszay M., Stockinger A., et al. Prevailing Opinions on Connected Health in Austria: Results from an Online Survey. Int J Environ Res Public Health. 2016;
18. Aastha Ahuja, Science and Health: What Is Telemedicine and Is India Ready for It?, NDTV (7 Dec. 2021), available at https://swachhindia.ndtv.com/science-and-health-what-is-telemedicine-and-is-india-ready-for-it-65296/ (last visited Dec. 15, 2025).
19. Organisation for Economic Co-operation and Development (OECD), The Future of Telemedicine after COVID-19 (OECD Policy Responses to Coronavirus, 20 Jan. 2023), available at https://www.oecd.org/en/publications/the-future-of-telemedicine-after-covid-19-d46e9a02.htm (last visited Dec. 15, 2025).OECD
20. OECD, The Future of Telemedicine after COVID-19 (2023) (noting that teleconsultations expanded rapidly during the pandemic as governments moved quickly to promote remote clinical consultations) (OECD Policy Responses to Coronavirus, 20 Jan. 2023), available at https://www.oecd.org/content/dam/oecd/en/publications/reports/2023/01/the-future-of-telemedicine-after-covid-19_3b64f3d8/d46e9a02-en.pdf (last visited Dec. 15, 2025).
21. Martin F. D’Souza v. Mohd. Ishfaq, (2009) 3 SCC 1 (India).
22. Ministry of Health and Family Welfare & NITI Aayog, Government of India, Telemedicine Practice Guidelines (25 March 2020), issued under the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002.
23. IQVIA Institute, Digital Health Trends 2024 (12 Dec. 2024).
24. Press Information Bureau, Govt. of India, Telemedicine and eSanjeevani (15 Jan. 2024).
25. Ministry of Health and Family Welfare, Govt. of India, Update on the implementation of Ayushman Bharat Digital Mission (13 Feb. 2025).
26. S. Sood et al., Adoption and utilization of India’s eSanjeevani national telemedicine service… (2025) (noting ABDM integration and ABHA-linked use), PubMed Central.
27. Press Information Bureau, Govt. of India, Digital Personal Data Protection (DPDP) Rules, 2025 (17 Nov. 2025) (notified 14 Nov. 2025).
28. MyGov (Innovate India), Draft Digital Personal Data Protection Rules, 2025 (3 Jan. 2025) (public consultation; implementation details including consent management direction).
29. TechRadar, India orders VPNs to block access to websites that unlawfully expose citizens’ data (11 Dec. 2025).
30. Axios, New Medicare trial may boost digital care (8 Dec. 2025) (chronic care payment model encouraging digital tools/remote monitoring).