In Freedom House's report on India[1] you can read about how they arrived at "partly free" for India. While the COVID lockdowns and their effect on marginalized groups where highlighted as events of 2020, if you look at the particular categories outlined below, you'll see that a lot more is going on that it warrants the rating of "partly free" in their opinion.

1: https://freedomhouse.org/country/india/freedom-world/2021