The Centre for Health Law Policy and Ethics (CLPHE) has submitted its comments on the Draft National Health Research Policy 2026 to the Department of Health Research within the Ministry of Health and Family Welfare on 27 July 2026, in response to the Department’s call for public comments. The submission discusses the Policy’s governance structure, ethics, data protection standards, and approach to translating research into public benefit. It concludes with 24 recommendations aimed at ensuring the Policy aligns more closely with the existing statutes and regulations governing this area.

Some of the notable recommendations from the submission include addressing a conflict between the Policy’s proposed single ethics review for multicenter research and the existing rules that require the reviewing committee and the trial site to be within 50 kilometres of each other. Additionally, the submission calls for safeguards against conflicts of interest, which are currently outlined only for ethics committees overseeing clinical trials, to be expanded to include committees reviewing non-trial biomedical research. Regarding data protection, the submission recommends that the Policy consider the phased implementation of the Digital Personal Data Protection Rules, 2025, as key provisions are not yet in effect. The submission also suggests recognizing palliative and end-of-life care as a distinct research priority, treating mental illness as a separate vulnerability distinct from intellectual disability, and specifying the law that governs the use of health research data to train AI models within the Policy.

These comments were submitted on behalf of the Centre by Dr. Madhubanti Sadhya and Bhanu Tanwar, Assistant Professors of Law and Co-Directors, CLPHE.

The full submission can be accessed here.