Certification Authorities already recognized by the root Certifying Authorities in any other country should automatically be considered as "Provisionally Recognized under Indian Cyber Law" and their certificates should be considered valid.

They should be subjected to Licensing only if they want to issue Digital Certificates to Individuals or Companies in India. Even in such a case, prior Government approval and Gazette notification should be waived.

If a Foreign Company which doesnot presently have a recognition in any other country wants to setup Digital Certificate service in India, only such companies may be subjected to prior approval of Government and Gazette Notification. 

Thepower of the Controller should be limited to suspension of   the license only. Revocation should be with prior approval from the Central Government and notification in the Gazette.

Revocation of a Licence could affect any Digital Certificate holder globally. Hence the notice of such revocation should be available to the whole world through an Electronic Gazette accessible on the Web.

The validity period  of the Licence should be a minimum of three years. The licence may be reviewed at annual intervals. The Controller may be permitted to suspend / revoke the license if required after a due process as per Sec 25 

The license should be transferrable subject to the approval of the Government. If this provision is not available, the Commercial Value of the Certification Business will suffer. It is also necessary if any of the existing Certificate Authority wants to exit or enrol a Joint  Venture Partner without affecting the existing customers. 

The controller should have powers only to suspend a Certification Authority. Revocation should be with prior approval of Government and notification in the Gazette.

Revocation of a License could affect any Digital Certificate holder globally. Hence the notice of such revocation should be available to the whole world through an Electronic Gazette accessible on the Web.

Power to delegate should not include suspension and revocation of Certifying authorities.

The office of the Certifying authority is not a place where the Netizens vistit physically. The requirement is therefore ridiculous. Many of the foreign Certifying authorities may like to operate without a physical office in India. This provision will block such a possibility.

It is sufficient if the web site of the Certifying authority through which Certificates are issued contains the display of a link to the Licence particulars. The actual license may be kept on the web site of the Controller.