Photo of Priyam Rajkumar

Priyam Rajkumar

Principal Associate - Designate in the Pharmaceutical, Life-sciences and Healthcare practice at the Delhi NCR office of Cyril Amarchand Mangaldas. Priyam graduated from the University of Edinburgh, United Kingdom in 2019 and completed his Bridge Course from the National Law University, Delhi in 2020 and specializes in regulatory compliance, advisory work, tender matters and litigation pertaining to the pharmaceutical, medical devices, digital health, clinical trials and the life-sciences industry. He also has prior experience in technology, media and telecommunications (TMT) advisory, education matters and labour and employment matters. He can be reached at priyam.rajkumar@cyrilshroff.com

When The Cover Gets Judged: Unboxing Cosmetics Packaging Obligations

Summary: Cosmetics packaging sits across overlapping regimes, spanning labelling accuracy, plastic waste management, and product-specific rules of their own. A single product may touch all three frameworks at once, raising issues from registration requirements to mislabelling liability to repercussions for missed EPR targets. The real challenge, however, lies in reliably seeing where they all converge on the same pack.

Continue Reading When The Cover Gets Judged: Unboxing Cosmetics Packaging Obligations
Mirror, Mirror on the Wall: The Rise of Personalised Cosmetics Regimens in India

Summary: With artificial intelligence increasingly driving the personalisation of skincare and beauty products in India, businesses operating at this intersection must navigate a complex and evolving regulatory landscape. This post examines the key legal considerations that arise when AI is used to design customised cosmetic regimens. It explores the classification risk where AI-driven analysis and tailored recommendations risk crossing the line from cosmetics into drugs or even software as a medical device. It then considers the interplay between product and service liability under the Consumer Protection Act, 2019, particularly where harm results not from a defective product per se, but from an AI algorithm’s failure to account for individual user characteristics.

Continue Reading Mirror, Mirror on the Wall: The Rise of Personalised Cosmetics Regimens in India

Summary: Whole genome sequencing has rapidly transitioned from a research tool to a routine diagnostic offering in India, now available through accredited laboratory chains and direct-to-consumer testing kits alike. Yet India lacks a single, dedicated law governing genomic testing; instead, existing frameworks for laboratory accreditation, clinical establishments, and medical devices reach WGS only incidentally, leaving significant gaps around informed consent, genetic counselling, and long-term data protection. A comparative look at the United Kingdom and the United States reveals more structured, albeit still evolving, approaches to regulating genetic diagnostics and consumer genomics. This blog examines the current Indian regulatory patchwork and makes the case for a purpose-built governance framework that addresses the unique, far-reaching implications of genomic information.

Continue Reading Decoding the Genome, Encoding the Law: Whole Genome Sequencing in Healthcare
Patchwork of Legal Classification: How Transdermal Patches reveal the fault lines in India’s Drug–Cosmetic Divide

Summary: This article explores the regulatory challenges surrounding acne and transdermal patches in India. An acne patch that promises to “reduce a blemish overnight” and a nicotine patch that delivers a measured dose through the skin look worlds apart. Yet under Indian law, both sit on the same unresolved line. Their classification determines whether a company needs only a cosmetic registration or a full drug license backed by clinical data, with any misclassification carrying serious risks.

Continue Reading Patchwork of Legal Classification: How Transdermal Patches reveal the fault lines in India’s Drug–Cosmetic Divide
Building the Missing Middle Piece: The Case for Micro-Hospitals in India

Summary: India’s healthcare delivery has long been shaped by two extremes: small clinics offering basic consultation and large corporate hospitals delivering advanced tertiary care. Micro-hospitals, typically comprising 15 to 75 beds, have emerged as the “missing middle”, combining lean infrastructure, digital diagnostics, and a sharper focus on patient experience. This blog examines the rationale for the micro-hospital model, its operational and economic advantages, and the extensive regulatory framework that governs hospital establishments of any size in India today.

Continue Reading Building the Missing Middle Piece: The Case for Micro-Hospitals in India
Breathing Life into Regulation: Case for ECMO Governance in India

Summary: Despite Extracorporeal Membrane Oxygenation (“ECMO”) gaining significance as part of critical care treatment in India, especially post-COVID-19, the regulations for ECMO treatment continue to be restricted to the Medical Devices Rules, 2017, and the device risk classification guidelines of the Central Drugs Standard Control Organization. This blog discusses the evolving regulatory regime in relation to ECMO in India, the lack of specific clinical governance protocols for ECMO treatment, and the need for such a protocol.

Continue Reading Breathing Life into Regulation: Case for ECMO Governance in India
Beyond The Siren: Rethinking The Role of Modern Ambulances

Summary: This article examines whether advanced ambulances, such as ALS vehicles and Mobile ICUs, could be classified as mobile clinics or Mobile Medical Units, attracting registration requirements as ‘clinical establishments’ under the Clinical Establishments Act, 2010. A review of the applicable regulatory framework indicates that ambulances and MMU/ mobile clinics serve fundamentally distinct purposes and are regulated differently, with ambulances presently not requiring clinical establishment registration solely by virtue of carrying medical equipment. However, as pre-hospital care continues to evolve, there is a growing need for a clearer regulatory framework to address the increasingly blurred boundaries between emergency transport vehicles and mobile healthcare delivery.

Continue Reading Beyond The Siren: Rethinking The Role of Modern Ambulances
The Cosmos of Cosmeceuticals in India

Summary: Cosmeceuticals are topical products with biologically active ingredients that blur the line between cosmetics and pharmaceuticals. Such products have gained significant market traction in India, yet occupy a regulatory grey zone with no independent legal status under the Drugs and Cosmetics Act, 1940. This ambiguity forces businesses to strategically navigate compliance by carefully crafting product claims to remain within the “cosmetic” category while avoiding the stricter regulatory requirements applicable to “drugs” or “medical devices”.

Continue Reading The Cosmos of Cosmeceuticals in India
Curbing Hospital and Surgeon Promotions in India: Regulation of Live Surgery Broadcasts

Summary: The NMC has issued new guidelines restricting live surgery broadcasts to curb patient exploitation, ensure ethical safeguards, and prevent commercial misuse. The framework shifts focus towards pre-recorded simulations and controlled teaching environments to balance education with patient rights.

Continue Reading Curbing Hospital and Surgeon Promotions in India: Regulation of Live Surgery Broadcasts