CYBER FRAUD LAWS IN INDIA AND THE UNITED STATES: A COMPARATIVE STUDY

CYBER FRAUD LAWS IN INDIA AND THE UNITED STATES: A COMPARATIVE STUDY

AUTHOR – MR. KANAV BHARDWAJ, LLM STUDENT AT GALGOTIAS UNIVERSITY

BEST CITATION – MR. KANAV BHARDWAJ, CYBER FRAUD LAWS IN INDIA AND THE UNITED STATES: A COMPARATIVE STUDY, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (9) OF 2026, PG. 261-268, APIS – 3920 – 0001 & ISSN – 2583-2344. DOI – https://doi.org/10.65393/IJLRV6I931

Abstract

The compounding growth of online transactions and reliance on network technologies has greatly raised cyber fraud in jurisdictions. India and the United States are two of the largest digital economies globally that have common yet distinct challenges in controlling cybercrimes. In this paper, a comparative study was made on the statutory systems, enforcement strategies, institutional frameworks, and adjudicatory systems of cyber fraud in both countries. Although India mostly employs the Information Technology Act, 2000 and the Indian Penal Code (recovery to the Bharatiya Nyaya Sanhita, 2023), in the United States the combination of the federal statutes (like Computer Fraud and Abuse Act, Wire Fraud Statute, state-based laws) are employed. The convergences noted in the study include criminalisation of unauthorised access, identity theft and financial fraud, whereas divergences occur following different constitutional cultures, enforcement ability and regulatory ideologies. The paper ends with a policy recommendation that will synchronize legal remedies, augment cross-border collaboration or coordination, and perpetuate victim-focused remedies.