Telegram Fz Llc & Anr. vs Union Of India & Ors.

* IN THE HIGH COURT OF DELHI AT NEW DELHI
Judgment Reserved on: 18.06.2026
% Judgment Delivered on: 19.06.2026
+ W.P.(C) 8259/2026 & CM APPL. 39036/2026
TELEGRAM FZ LLC & ANR. .....Petitioners
versus
UNION OF INDIA & ORS. .....Respondents
Advocates who appeared in this case
For the Petitioners : Mr. Dhruv Mehta, Senior Advocate
along with Mr. Madhav Khosla, Mr.
Abhi Udai Singh Gautam, Ms.
Roshni Ojha and Mr. Keith Verghese,
Advocates.
For the Respondents : Mr. Tushar Mehta, Solicitor General
of India & Mr. Chetan Sharma, ASG
with Mr. Ashish K. Dixit, Mr. Aman
Mehta, Mr. Umar Hashmi, Mr. Amit
Gupta, Ms. R.V. Prabhat, Mr.
Shubham Sharma, Mr. Yash Wardhan
Sharma and Mr. Naman, Advs. for R-
1 & 2.
Mr. R. Venkatramani, Attorney
General for India for R-1 & R-2.
Mr. Sanjay Khanna, Standing
Counsel along with Ms. Pragya
Bhushan, Ms. Jaya Choudhary & Mr.
Saurabh Pandey, Advs. for R-3.
CORAM:
HON'BLE MR. JUSTICE TEJAS KARIA
Signature Not Verified
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

JUDGMENT
TEJAS KARIA, J
1. This Writ Petition has been filed under Articles 226 and 227 of the
Constitution of India, 1950 for quashing and setting aside of the interim
order dated 16.06.2026 (“ Impugned Order ”) passed by Respondent No. 1,
Union of India, through Ministry of Electronics and Information Technology
(“ MeitY ”).
2. MeitY passed the Impugned Order under Section 69A of the
Information of Technology Act, 2000 (“ IT Act ”) on the request made by
Respondent No. 2, Ministry of Home Affairs (“ MHA ”) and Respondent No.
3, National Testing Agency (“ NTA ”).
3. After filing of the present Writ Petition, Respondent No. 1 has passed
the final order dated 18.06.2026 (“ Final Order ”) confirming the directions
contained in the Impugned Order (collectively “ Orders ”).
FACTUAL MATRIX
4. NTA vide letter dated 21.05.2026 informed MeitY of the misuse of
Telegram Application (“ Telegram ”) of Petitioner No. 1, Telegram FZ LLC ,
by third-parties in respect of the National Eligibility-cum-Entrance Test
(Undergraduate) 2026 (“ NEET UG, 2026 ”).
5. MeitY issued a notice dated 01.06.2026 (“ Notice ”), convening a
meeting on 03.06.2026 (“ Meeting ”) with the Petitioners and NTA to
consider the scale and nature of the alleged misuse of Telegram by third
parties in relation to NEET UG, 2026. The Petitioners, vide e-mail dated
01.06.2026, acknowledged receipt of the Notice issued by MeitY. Prior to
the Meeting, the Petitioners submitted a detailed response dated 02.06.2026
(“ Reply ”) to the Notice, addressing the issues raised therein.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

6. The Meeting was held as scheduled and was attended by the Parties.
Thereafter, the Petitioners, vide e-mail dated 04.06.2026, addressed a post-
Meeting communication summarising the discussions that had taken place
during the Meeting in relation to the issues concerning NEET UG, 2026, as
raised by MeitY.
7. MeitY issued a document dated 05.06.2026 recording the minutes of
the Meeting (“ Minutes of Meeting ”). The Petitioners, vide e-mail of the
same date, disputed the Minutes of Meeting as issued by MeitY and
furnished their clarifications thereto.
8. Thereafter, vide e-mail dated 09.06.2026, MeitY shared with the
Petitioners a list of URLs pertaining to Telegram channels, accounts and
bots, in respect whereof complaints had been received alleging their
involvement in fraud relating to the NEET UG, 2026 examination. The
Petitioners, vide e-mail dated 05.06.2026, acknowledged receipt of the said
list of URLs shared by MeitY and informed MeitY that the said URLs had
been taken down.
9. On 16.06.2026, Respondent No. 1, by way of the Impugned Order,
issued the following directions:
i. Telegram and its associated URLs to be blocked across India within
one hour of the receipt of the Impugned Order, till 22.06.2026;
ii. Telegram to disable the message editing feature till 30.06.2026;
iii. The Department of Telecommunication to instruct application
stores and internet service providers to block / disable access to
Telegram till 22.06.2026; and
iv. The Designated Officer to place the matter before the Committee
under Rule 7 of the Information Technology (Procedure and
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
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Safeguards for Blocking for Access of Information by Public)
Rules, 2009 (“ 2009 Rules ”) for consideration and recommendation
within 48 hours of issuance of the Impugned Order.
10. Aggrieved by the Impugned Order, the present Writ Petition has been
instituted by the Petitioner.
11. Thereafter, the Committee of Respondent No. 1 under Rule 7 of the
2009 Rules passed the Final Order, wherein upon consideration of the
material placed before it, including the Impugned Order, reports of NTA and
the Indian Cybercrime Coordination Centre (“ I4C ”), and after affording a
hearing to the Parties on 17.06.2026, concluded that Telegram was being
repeatedly misused in connection with fraud relating to NEET UG, 2026,
inter alia , by facilitating the circulation of misleading information
concerning the said examination.
12. Respondent No. 1 further observed that, despite repeated takedown
measures and engagement, unlawful channels continued to re-emerge
through backup channels and bots, thereby rendering narrower measures
ineffective. Having regard to the fact that the NEET UG, 2026 re-
examination was scheduled to be conducted on 21.06.2026, the Committee
concluded that a temporary platform-wide blocking of Telegram, along with
disabling of the message-editing feature, was necessary and proportionate
for protecting the integrity of the examination and maintaining public order.
Accordingly, Respondent No. 1 confirmed the Impugned Order issued under
Section 69A of the IT Act with immediate effect.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

SUBMISSIONS ON BEHALF OF THE PETITIONERS
13. Mr. Dhruv Mehta, learned Senior Counsel for the Petitioners made the
following submissions:
13.1. Petitioner No. 1 is a Limited Liability Company registered in the
United Arab Emirates having its registered office in Dubai and is
governed by the laws of the UAE. Petitioner No. 2, Major
Lakshmiraj Rathore, is the Nodal Officer and Authorised
Signatory of Petitioner No. 1 in India.
13.2. The Petitioners submitted that had extended sustained and bona
fide cooperation to the Respondents, particularly from 20.05.2026,
when the Respondents began convening meetings concerning the
alleged circulation of fraudulent content relating to NEET
UG, 2026.
13.3. Vide the Reply, the Petitioners informed MeitY that Telegram
does not permit its services to be used for examination fraud,
cheating, impersonation, or the sale or distribution of examination
material. The Reply also stated that Telegram maintains an
extensive content-moderation framework, comprising artificial
intelligence and machine-learning tools, hash-based detection
mechanisms, and human moderators who proactively review
content and remove unlawful material.
13.4. The Reply further highlighted that users may report suspicious
content through in-app reporting tools, while anti-spam systems,
privacy controls, and warning labels such as “scam” and “fake”
operate to prevent misuse. Strict enforcement measures, including
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

content removal, account restrictions, and permanent bans, were
imposed upon violators relating to NEET UG, 2026.
13.5. However, the Impugned Order neither discloses adequate reasons
for imposing a platform-wide block on Telegram, nor does it
explain why such an extreme measure was necessary to address
content relating to NEET UG, 2026. The Impugned Order,
according to the Petitioners, failed to undertake any meaningful
proportionality assessment and disregards the impact of the
measure on the Petitioners as well as on more than 150 million
Telegram users in India. The Impugned Order overlooks the fact
that millions of students and educators use Telegram for lawful
and constitutionally protected purposes, including sharing study
material and educational resources for NEET preparation, thereby
resulting in the restriction of legitimate content along with
allegedly unlawful content.
13.6. In the present case, the requisite satisfaction was not that of the
Secretary, but of the Committee while passing the Final Order.
Reliance was placed on Rule 9(4) of the 2009 Rules, which
provides that the Secretary, Department of Information
Technology, is required to pass a final order after considering the
recommendations of the Committee on the blocking request. It
was further submitted that, where such request is rejected, the
interim blocking order must be revoked and public access to the
information restored.
13.7. After the passing of the Impugned Order, the Petitioners complied
with the directions issued therein. In particular, the Petitioners
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

disabled 900 URLs out of the 1300 URLs communicated to them
by MeitY vide e-mails dated 09.06.2026. However, the Impugned
Order is silent on the compliance made by the Petitioner.
13.8. Reliance was placed on the decision in Anuradha Bhasin v.
Union of India , (2020) 3 SCC 637, wherein the Hon’ble Supreme
Court held that restrictions on fundamental rights must be
proportionate and that only the least restrictive measure may be
adopted while imposing such restrictions. The requirements of the
doctrine of proportionality must be considered before any order
restricting fundamental rights is passed. In the present case, MeitY
and MHA failed to adopt less restrictive alternatives, such as
directing the takedown of specific offending posts or channels,
instead of blocking the application as a whole. The Petitioners had
consistently complied with takedown directions and remained
willing to assist the Respondents in addressing any additional
violations promptly.
13.9. The Impugned Order erroneously concludes that the Petitioners
failed to discharge their obligations under Rule 3(1)(b) of the
Information Technology (Intermediary Guidelines and Digital
Media Ethics Code) Rules, 2021 (“ 2021 Rules ”), without
identifying the reasonable measures allegedly required to be
undertaken. The Petitioners had adopted all reasonable and
technologically feasible safeguards to curb unlawful content and
had complied with their statutory obligations.
13.10. The Impugned Order errs in concluding that the Petitioners failed
to take sufficiently effective measures to address content relating
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

to NEET UG, 2026, particularly since the contextual and
subjective nature of such content necessarily limits the efficacy of
artificial intelligence and machine-learning-based moderation
mechanisms. The standard of compliance applicable to an
intermediary is one of reasonable measures and due diligence.
Accordingly, MeitY and MHA cannot attribute failure to the
Petitioners merely on the ground that available technology has not
achieved perfect results.
13.11. Reliance was also placed on the decision in Bishamber Dayal
Chandra Mohan v. State of U.P. , (1982) 1 SCC 39, wherein the
Hon’ble Supreme Court held that any restriction placed upon the
exercise of a fundamental right must be proportionate, reasonable,
and strictly confined to what is necessary in the public interest,
and must not exceed such limits as would render it arbitrary or
excessive.
13.12. The Impugned Order is ultra vires Section 69A of the IT Act,
insofar as it directs the blocking of the entire Telegram platform.
According to the Petitioners, Section 69A of the IT Act empowers
MeitY only to block access to specific “ information ” and does not
confer authority to impose a blanket restriction on an entire
intermediary platform.
13.13. The procedure prescribed under the 2009 Rules requires the
Secretary, MeitY, to independently apply his mind to the facts and
to the recommendations of the Designated Officer, and does not
permit mechanical confirmation thereof. On this ground alone, the
Impugned Order is procedurally unsustainable in law.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

13.14. In view of the foregoing submissions, it was submitted that the
Impugned Order and the consequential Final Order are liable to be
quashed and set aside on the grounds of non-application of mind,
procedural irregularity, and disproportionality of the measure
adopted, namely, the blocking of the entire Telegram platform to
achieve the stated objective, thereby affecting the rights of
millions of users who were not alleged to have been involved in
any unlawful activity sought to be curbed.
SUBMISSIONS ON BEHALF OF MEITY AND MHA
14. Mr. Tushar Mehta, learned Solicitor General of India along with Mr.
Chetan Sharma, learned Additional Solicitor General of India appearing for
MeitY and MHA, made the following submissions:
14.1. MeitY had received multiple complaints concerning the misuse of
Telegram, the first of which was received from NTA vide letter
dated 21.05.2026, disclosing specific instances of bots and
channels allegedly linked to examination paper leaks, thereby
endangering the integrity of the NEET UG, 2026 examination
process involving approximately 2.2 million candidates across the
country. MeitY and MHA, being conscious of the doctrine of
proportionality, initially adopted a measured course by convening
the Meeting, which demonstrated that actions of the Respondents
were calibrated and in accordance with the principles of
proportionality.
14.2. In compliance with Rule 9 of the 2009 Rules, due intimation was
issued to the Petitioners within the prescribed period of 48 hours,
and a personal hearing was afforded before the Committee on
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

17.06.2026. Thereafter, the Committee passed the Final Order,
which is a detailed and reasoned order, upon due consideration of
the Petitioners’ submissions. In view of the passing of the Final
Order, the present Petition has been rendered academic, as all
contentions raised therein stood considered and adjudicated upon
by the Committee in accordance with the 2009 Rules.
14.3. Telegram can be materially distinguishable from other
intermediary platforms on account of its distinctive technical
architecture, including cloud-based infrastructure, large public
broadcast channels, automated bot ecosystems, concealment of
user identifiers, large-volume file-sharing capabilities, and self-
destructing messages, which cumulatively create an ecosystem
particularly susceptible to misuse.
14.4. Telegram’s message-editing functionality permits posts to be
altered in a manner that may make content appear as though it had
been published on an earlier date. In the context of examination
fraud, such functionality can pose a grave threat to public order
affecting a large number of students, particularly when contrasted
with comparable intermediaries that incorporate a standard
“edited” label as a matter of course.
14.5. Telegram, vide reply dated 17.06.2026, acknowledged the
unavailability of its services in India, while also stating that it
could not prevent users from bypassing blocking measures
through VPNs. Telegram further stated that it was in the process
of introducing a more prominent “edited” label, thereby proposing
an architectural change that would require considerable time for
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

implementation. In these circumstances, the temporary disabling
of the message-editing functionality constitute a tailored,
proportionate, and event-specific precautionary measure confined
to the context of examination fraud and falling well within the
bounds of permissible restrictions.
14.6. A Telegram channel titled “ NEET Mafia ”, having approximately
18,000 subscribers, had been identified as actively disseminating
material purporting to relate to NEET UG, 2026 examination
leaks, advance booking arrangements, and payment collection
mechanisms, thereby illustrating Telegram’s capacity to facilitate
mass unlawful dissemination to thousands of users simultaneously.
14.7. Removal of a Telegram channel does not extinguish its subscriber
base, since Telegram’s architecture permits the instantaneous
creation of mirror channels to which existing subscribers may be
redirected, thereby enabling unlawful activities to resume almost
immediately despite takedown action.
14.8. NTA specifically confirmed that, despite repeated takedown
actions against identified channels and accounts, the fraudulent
ecosystem continued to spread through new channels, backup
channels, rotated handles, and burner accounts. This pattern
intensified prior to the re-conduct of NEET UG, 2026, thereby
demonstrating that targeted enforcement measures had been
rendered inadequate by the rapid creation of replacement
infrastructure and that, in circumstances involving public order
concerns, prohibition of the platform of the intermediary itself
became imperative.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

14.9. Section 2(1)(v) of the IT Act defines “ information ” expansively to
include data, messages, text, images, sound, voice, codes,
computer programmes, software, and databases. Such definition is
not confined merely to individual messages, posts, or files, but
extends to the underlying technological components through
which content is generated, transmitted, received, stored, or
hosted. An application or software platform, being a compilation
of codes, computer programmes, databases, application
programming interfaces, and communication protocols, was stated
to fall within the broad definition of “ information ”.
14.10. The blocking power under Section 69A of the IT Act extends
beyond individual pieces of content and, having regard to its wide
legislative scope, encompasses the software architecture,
codebase, databases, and programmatic ecosystem constituting an
application. Since such an application qualifies as an aggregation
of “ information ” under Section 2(1)(v) of the IT Act, the
Impugned Order directing the blocking of Telegram in its entirety
was consistent with the authority conferred under Section 69A of
the IT Act.
14.11. I4C report dated 10.06.2026 documented the widespread
exploitation of Telegram for unlawful activities, including cyber-
attacks, malware distribution, transnational cybercrime,
circulation of leaked examination papers, and circulation of child
sexual exploitative and abuse material, thereby establishing
systemic misuse of the Telegram platform. Accordingly, the
expression “any information” under Section 69A of the IT Act is
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SHARMA
Signing Date:19.06.2026
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sufficiently broad to encompass all information hosted by an
intermediary where the scale of harm so warrants.
14.12. Reliance was placed upon the decision in Assistant General
Manager, State Bank of India & Anr. v. Tanya Energy
Enterprises through its Managing Partner Shri Alluri Lakshmi
Narsimha Varma , Neutral Citation: 2025 INSC 1119, wherein the
Hon’ble Supreme Court has held that a Court is not invariably
bound by the grounds expressly stated in an administrative order
and may, in appropriate cases, uphold such order on an alternative
ground traceable to the factual narrative therein, subject to
affording the affected party due notice and an opportunity to
respond.
14.13. Reliance was also placed upon the decision in Akshay N. Patel v.
Reserve Bank of India & Anr. , (2022) 3 SCC 694, wherein the
Hon’ble Supreme Court held that constitutional rights cannot be
permitted to become instruments in the hands of private
commercial entities to defeat lawful regulation enacted in public
interest.
14.14. The doctrine of proportionality requires a careful balancing of
potential private harm against public harm. In the present case,
Telegram’s architectural design, particularly its mass-
multiplication features and date-time editing capability, rendered
it structurally incapable of preventing misuse during the critical
examination window. Reliance was placed upon Anuradha
Bhasin ( supra ) in support of the said submission.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
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14.15. In view of the foregoing submissions, it was submitted that the
present Petition is liable to be dismissed.
15. Mr. R. Venkatramani, learned Attorney General for India, while
buttressing the submissions advanced by the learned Solicitor General of
India, submitted that the Impugned Order was passed upon due application
of mind and is complete in itself. It was further submitted that an entity
which, by reason of its own technical architecture, is structurally incapable
of ensuring accountability, cannot be permitted to invoke the doctrine of
proportionality to assail lawful regulatory action. It was also submitted that a
profit-driven commercial platform cannot selectively rely upon
proportionality to resist legitimate preventive measures adopted by the State
in public interest.
REJOINDER SUBMISSIONS ON BEHALF OF THE PETITIONERS
16. Mr. Dhurv Mehta, learned Senior Counsel for the Petitioners made the
following rejoinder submissions:
16.1. The Government cannot, under the guise of exercising powers
under Section 69A of the IT Act, resort to wholesale blocking of
the internet or of an entire intermediary platform. Reliance was
placed upon the decision in Anuradha Bhasin ( supra ) in support
of the said submission.
16.2. Although the Short Affidavit dated 18.06.2026 filed by MeitY
and MHA in the present Petition raises concerns regarding the
detection of unlawful content on Telegram, such concerns are
misplaced. The Petitioners do not suffer from any technological
deficiency and possess the requisite capability to detect unlawful
content circulated on Telegram.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
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16.3. The challenge in the present Petition is not confined merely to
procedural lapses but extends to the absence of any platform-
specific or architectural basis sufficient to justify the invocation of
emergency powers against Telegram.
i. On the procedural aspect, the Impugned Order suffers from
non-application of mind, having accepted general allegations
at face value without particular evidence and independent
assessment of proportionality of the action taken. The
Petitioners have been proactively engaging with the
Respondents since 20.05.2026, demonstrating prompt
compliance with takedown requests, and specifically flagged
the adverse impact of such blocking on students dependent on
Telegram for their NEET UG, 2026 preparations.
ii. On the architectural aspect, the Minutes of Meeting do not
accurately reflect the discussion held at the Meeting. The
Petitioners’ e-mail dated 05.06.2026 acknowledging the
Minutes of Meeting also entail clarifications specifically
clarifying that its moderation framework encompasses
extensive proactive and reactive measures and that the
references made during the Meeting to contextual limitations
and search functionality were taken out of context and do not
suggest any deficiency in Telegram’s technological capability
to address the issue of unlawful content.
16.4. The Petitioners maintain a zero-tolerance approach towards
unlawful activity and undertake proportionate enforcement action
by utilising all identifiers available within Telegram’s technical
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architecture. The Petitioners continuously enhance their detection
and enforcement mechanisms in accordance with Telegram’s
technical framework and applicable legal obligations.
16.5. The Petitioners are in due compliance with Rules 3(1)(b) and
3(1)(d) of the 2021 Rules, and that such compliance negates the
justification advanced by MeitY and MHA for invoking
emergency powers against Telegram.
17. In view of the foregoing submissions, it is prayed that the present
Petition be allowed and the Orders be set aside.
ANALYSIS AND FINDINGS
18. Heard the learned Senior Counsel for the Petitioner, learned Attorney
General for India, learned Solicitor General of India and learned Additional
Solicitor General of India for the Respondents.
19. Upon consideration of the rival submissions advanced on behalf of the
Parties and the material placed on record, the following issues arise for
determination:
i. Whether the Impugned Order passed by Respondent No. 1 is
vitiated by non-application of mind?; and
ii. Whether the action of Respondent No. 1 in temporarily blocking
public access to entire Telegram platform satisfies the requirement
of proportionality?
Issue (i)
20. In respect of the present issue, the principal contention advanced on
behalf of the Petitioners is that the Impugned Order suffers from non-
application of mind, and that the Final Order confirming the Impugned
Order cannot supply or supplement reasons that are absent from the
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SHARMA
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Impugned Order itself. According to the Petitioners, the language employed
in the Impugned Order demonstrates that Respondent No. 1 merely
reproduced the relevant ingredients of Section 69A of the IT Act, without
undertaking an independent assessment of the material placed before it,
thereby creating only an appearance of compliance with the said provision.
21. In this regard, it would be apposite to advert to the relevant portion of
the Impugned Order, which is reproduced hereinbelow:
“ Whereas, section 69(A) of the Information Technology Act, 2000
and Rules made thereunder empower the Central Government to
issue directions for blocking for public access of any information
through any computer resource, if it is satisfied that it is necessary
or expedient so to do, in the interest of sovereignty and integrity of
India, defence of India, security of the state, friendly relations with
foreign States or public order or for preventing incitement to the
commission of any cognizable offence relating to above, it may
direct any agency of the Government or intermediary to block for
access by the public or cause to be blocked for access by the public
any information generated, transmitted, received, stored or hosted
in any computer resource.
And whereas, the Designated Officer appointed under the
Information Technology (Procedure and Safeguards for Blocking
for Access of Information by Public) Rules, 2009 (hereinafter
referred to as the Rules) has received request from designated Nodal
Officer for blocking of the messaging platform intermediary
Telegram and its associated URLs under the emergency provisions
u/s 69A of IT Act, 2000.
And whereas, the requesting agency Ministry of Home Affairs and
the NEET examination authority, NTA has brought to the notice of
MeitY about the growing misuse of the intermediary Telegram in the
circulation of fake examination papers, dissemination of misleading
information, and other fraudulent illegal activities relating to NEET
(UG) 2026. In the request, the agencies further highlighted that
despite repeated takedown actions against specific channels, the
fraudulent ecosystem continues to proliferate on the Telegram
platform through the creation of new channels, groups, and
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SHARMA
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associated infrastructure. In view of the serious implications for the
integrity of the examination process and in the interests of a large
number of students appearing in the examination, the agency MHA
requested that access to the intermediary "Telegram" be blocked for
nd
at least till 22 June by which time the examination process would
rd
have concluded. A meeting with Telegram was held on 03 June
2026 with officials of NTA and MeitY, wherein serious concerns
regarding the misuse of the Telegram platform for dissemination of
examination-related misinformation, circulation and selling of
purported examination papers, and other fraudulent activities were
brought to the notice of Telegram. Despite such engagement and
repeated reporting of objectionable channels, as per the nodal
officer the misuse has not abated and has even intensified before re-
conduct of NEET Examination. As per the agencies, the same
Telegram operators continue to circulate false claims of an
impending paper release, using rotated handles pre-positioned
backups and burner accounts that have rendered channel-by-
channel takedown ineffective. Students continue to be defrauded,
and the persistent rumour-mongering is calculated to undermine
public confidence in the integrity of the re-conducted examination at
its most sensitive juncture. The agencies further submitted that the
reactive, entity-by-entity approach has been exhausted and that
nothing short of a platform -level measure will secure the
examination through the critical window and accordingly the
agencies requested for the blocking of Telegram and its associated
URLs under the emergency provisions of Section 69A of the
Information Technology Act, 2000.
And whereas, the Designated Officer has examined the emergency
requests received from Nodal Officer related to blocking of
Telegram application and its associated URLs. The Designated
Officer observed that NEET is conducted by NTA once in a year
which is country's sovereign exercise to select the right candidates
for MBBS course and there has already been an incident where
some miscreants exploited Telegram platform to spread fake
information and to carry out fraudulent activities. Even after
discussions with the Telegram officials, the Telegram platform failed
to effectively curb such activities or take any effective preventive
measures on their platform which resulted in wide spread public
unrest in the country. A repeat of such lack of pre-emption on the
platform and continuous propagation of similar contents/activities
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SHARMA
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will again create public order situations in the country besides
undermining the credibility of the public institutions like NTA. It is
also highlighted that Law Enforcement Agencies from various States
including Bihar, Rajasthan and Gujarat, have made several arrests
and already issued advisories to general public to stay alert about
the NEET paper leak scam which is being used to defraud students
and their families. Further, NTA in its supplementary technical note
specifically highlighted how the message editing feature with
timestamp retention was exploited by the fraudulent actors to create
leaked chat artifacts and mislead the NEET aspirants. A repetition
of the same will again create panic among students and parents and
st
will seriously hamper the integrity of the exam scheduled on 21
June, as also inflame the sentiments of the aspirants. To prevent any
such adverse effects by spreading false and misleading information
in relation to the re-conduct of the NEET UG 2026 examination, the
Designated Officer after careful examination of the request along
with the accompanying information and to his satisfaction, under
Rule 9(1) of the Rules, has made specific recommendation to block
for access by the public or cause to be blocked for access by the
public any information generated, transmitted, received, stored or
hosted in any computer resource by messaging platform
nd
intermediary Telegram and its associated URLs till 22 June 2026
and to direct the messaging platform intermediary Telegram to
th
disable the message editing feature till 30 June 2026, as there is a
cogent apprehension that the referred to fraudulent illegal activities
on the platform might pose serious challenges to the public order in
the country.
And whereas, on communication of the recommendations of the
Designated Officer and having perused the material available on
file, I, Secretary, Ministry of Electronics & Information Technology
have satisfied myself that the Telegram platform is misused for the
dissemination of examination-related misinformation, circulation of
purported examination papers, and other fraudulent illegal activities
that can have serious implications on the public order in the
country.
Now therefore, I hereby allow the recommendations of Designated
officer as an interim measure. I hereby direct the messaging
platform intermediary Telegram to be blocked for access by the
public or cause to be blocked for access by the public any
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Signing Date:19.06.2026
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information generated transmitted received, stored or hosted in any
computer resource by Telegram and its associated URLs in India
nd
within 1 hour of receipt of this order till 22 June 2026 and to
th
disable the message editing feature till 30 June 2026 in the interest
of sovereignty and integrity of India, public order and to prevent
commission of any cognizable offence relating to public order. I also
direct Department of Telecommunication to issue directions to ISPs
and various App stores to block for access by the public or cause to
be blocked for access by the public any information generated,
transmitted, received, stored or hosted in any computer resource by
messaging platform intermediary Telegram and its associated URLs
from their platform within 1 hour of receipt of this order till 22nd
June, As per Rule 16 of above stated Rules, you are instructed to
strictly maintain confidentiality regarding the actions taken in
pursuant to this direction, and no part of this communication should
be made public. I also direct the Designated Officer to place the
request before the Committee referred to in rule 7 of the Rules for its
consideration and recommendation within 48 hours of issuance of
this interim order. ”
22. A perusal of the Impugned Order indicates that Respondent No. 1,
upon consideration of the material placed before it, was satisfied that
Telegram was being misused for dissemination of examination-related
misinformation, circulation of purported examination papers, and other
fraudulent and unlawful activities, which were likely to have serious
implications for public order in the country. Upon recording such
satisfaction, Respondent No. 1 directed that public access to Telegram be
blocked until 22.06.2026 and that the message-editing feature be disabled
until 30.06.2026, with a view to prevent the commission of cognizable
offences relating to public order.
23. There is no cavil that every decision of a statutory or administrative
authority must be supported by reasons, which constitute an essential facet
of the principles of natural justice. Reasons serve to establish the nexus
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between the material placed before the authority and the conclusion arrived
at by it and further demonstrate that the authority has applied its mind to the
relevant facts and circumstances.
24. In the present case, the Impugned Order discloses that temporary
blocking of the public access to Telegram is directed having regard to the
potential grave implications for public order in the country and for
preventing the commission of cognizable offences arising from the
circulation of examination-related misinformation and purported
examination papers on Telegram, particularly in light of prior incidents
relating to NEET UG, 2026.
25. Thus, this Court is of the view that given the emergency nature of the
Impugned Order, the reasons supplied in arriving at the decision were
sufficient. As Respondent No. 1 has strictly followed the procedural steps as
required under Section 69A of the IT Act, the challenge to the Impugned
Order on the ground non-communication of reasons cannot be sustained.
Accordingly, the objections founded on alleged non-application of mind and
inadequacy of opportunity of hearing also fail given the statutory scheme of
Section 69A of the IT Act and 2009 Rules. In view of the foregoing, this
Court is of the considered opinion that the Impugned Order contains reasons
and there exists a direct and substantial nexus between the direction issued
and the reasons assigned.
26. Further, an opportunity of hearing was afforded to the Petitioners
immediately after the passing of the Impugned Order in terms of 2009
Rules. The Final Order was, thereafter, passed upon due consideration of the
submissions advanced by the Petitioners before the Committee, recording
detailed reasons in support of the continued blocking of public access to
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Telegram. The relevant portion of the Final Order is reproduced
hereinbelow:
“ 1. Background
These proceedings arise from the Interim Direction dated 16th June
2026 issued under Rule 9 of the Blocking Rules, in view of the
imminent conduct of the NEET (UG) 2026 re-examination scheduled
for 21st June 2026.
The Interim Direction was based on material received from the
National Testing Agency (NTA), the Indian Cybercrime
Coordination Centre (I4C), and other competent agencies, which
collectively established the continuing misuse of the Telegram
platform in connection with examination-related fraud. NTA
communicated, through successive letters, that channels were
operating openly on the platform under names that themselves
advertised their unlawful purpose — including "PAPER LEAKED
NEET", "Re-NEET 2026", "Private Mafia", and "REE NEET
MAFIAA" — and were demanding sums ranging from a few
thousand to several lakhs of rupees from candidates and their
families in exchange for purported access to re-examination
material.
I4C additionally reported that Telegram was being utilised for a
range of other unlawful activities, including child sexual
exploitation and abuse material (CSEAM), deepfake content, digital
arrest fraud, command-and-control malware deployment, and
sextortion. The record establishes that I4C pursued consultations
and sought corrective measures from the platform on at least 35
separate occasions since October 2024.
2. Supporting Documents Considered
The Committee has considered the following material:
(i) NTA communications dated 21st May 2026 and 15th June
2026;
(ii) Telegram’s written responses and submissions;
(iii) Minutes of the meeting held at MeitY on 3rd June 2026;
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(iv) Recommendations of I4C/MHA dated 15th June 2026;
(v) The Interim Direction dated 16th June 2026; and
(vi) Oral submissions made before the Committee under Rule 7
on 17th June 2026.
3. Contentions Raised by Telegram
Telegram submitted that it operates extensive content moderation
systems, including AI/ML-assisted detection tools, human
moderation, user reporting mechanisms, and enforcement
procedures, and that it had acted upon reported entities and
maintained cooperation with Indian authorities. Telegram further
contended that:
(a) Invocation of Rule 9 was unwarranted, given that
engagement had been ongoing for several weeks;
(b) A platform-wide block was disproportionate, and that
specific channels, groups, or accounts ought to have been
targeted instead;
(c) Telegram had already implemented proactive compliance
measures; and
(d) Section 69A does not authorise the blocking of a platform
in its entirety.
4. Findings on Invocation of Rule 9
Telegram has been fully heard. All material has been duly perused;
the Committee has bestowed its due consideration on the
contentions raised and the material on record. The Committee does
not accept the contention that prior engagement necessarily negates
the existence of an emergency. The record demonstrates that
Government authorities pursued consultations and sought corrective
measures at least 35 times since October 2024 on various misuses of
the platform. However, the fresh material including reports by the
NTA and the Indian Cybercrime Coordination Centre (I4C),
Ministry of Home Affairs, received immediately prior to the
examination to be held on 21.06.2026, revealed the continuing and
startling emergence of unlawful entities, reserve channels, audience
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migration structures and fraudulent activity despite prior
interventions.
The emergency arose not from first discovery of the issue, but from
the escalation and persistence of the identified threat in the
immediate run-up to the examination. In the Committee's view,
waiting for completion of the ordinary process would have
materially undermined the objective of preserving the integrity of the
examination process. Any non-action by the government would have
necessarily led to compromising the sanctity and integrity of the
examination process. More so, as this was the re-examination of
NEET. Therefore, the Committee could not be unmindful of the
paramount interests of the 22 lakh candidates and their families and
the resultant chaos and the potential disruption of public order. The
Committee also took serious note of the fact that unscrupulous
entities were riding on the platform with barcodes to elicit illegal
payments from students across the length and breadth of India. This
pattern of money-making and exploitative conduct employed by the
exam mafia/syndicates on this platform cannot be countenanced.
5. Findings on Necessity and Adequacy of Alternatives
The Committee carefully examined whether less restrictive
alternatives existed which could adequately address the identified
harm. Entity-specific interventions, including reporting and removal
of channels, groups, bots and accounts, were repeatedly found
ineffective and inadequate. The record nevertheless demonstrates
the recurring reappearance of offending entities through mirror
channels, backup channels, reserve channels and successor entities.
The platform has clearly failed in its statutory obligation and its
purported compliances are inadequate and ineffective. There is
repeated emergence and re-emergence of user accounts, backup
channels, bots and auto-rotated handles, all of which successfully
dodged all takedowns and bypassed all directives.
Committee observed that due to the platform's complex, proprietary
technical architecture and the highly dynamic, high-volume nature
of user-generated data, the real-time segregation of legitimate
communications from illicit content is practically unfeasible.
Because granular filtration is technically impossible at this scale,
and with critical exam timelines immediately approaching, a
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comprehensive block on the platform remains the only viable
mechanism of last resort to eliminate systemic risk and prevent
widespread institutional compromise which was agreed by the
committee.
The evidence further demonstrates that audience migration
mechanisms enabled operators to rapidly reconstitute networks
following enforcement actions. Accordingly, the Committee
concludes that channel-specific measures had not proved capable of
providing an effective and timely remedy in the prevailing
circumstances when re-examination of NEET(UG) is scheduled on
21st June, 2026.
6. Findings on Platform Characteristics
The Committee notes that certain features of the Telegram platform
assumed particular relevance in the factual circumstances of this
case: specifically, its large public channels, extensive file-sharing
capabilities, automated bot functionality, username-based
operation, reserve-channel structures, and rapid audience migration
capabilities.
The Committee does not regard these features as unlawful in
themselves. However, the material before it establishes that these
features were actively and systematically utilised by the identified
network to evade enforcement measures and to sustain unlawful
activity during the critical pre-examination period.
7. Findings on Proportionality
The Committee does not proceed on the assumption that all content
on Telegram is unlawful. The measure is grounded in the
demonstrated inability of narrower interventions to effectively
mitigate the identified risk within the available time. The restriction
was temporary, event-linked, and limited in duration.
The Committee finds that the measure bears a rational nexus to the
objectives sought to be achieved — namely, the protection of
examination integrity, the prevention of fraud, and the preservation
of public confidence in the examination process. The measure is
accordingly held to satisfy the requirement of proportionality.
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Signing Date:19.06.2026
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8. Jurisdiction Under Section 69A
The present case clearly falls within the ambit of public order and
for preventing incitement to the commission of any cognizable
offence relating to public order, which falls under one of the clauses
of Section 69A.
Telegram functions as an intermediary operating through software
applications, databases, servers, and network infrastructure
constituting “computer resources” within the meaning of the
Information Technology Act, 2000. Information generated,
transmitted, received, stored, or hosted through such resources falls
within the scope of Section 69A.
The Committee is satisfied that the present action is directed not
against Telegram merely by reason of its status as an intermediary,
but because the material on record establishes that access to the
relevant computer resource was being repeatedly and systematically
exploited for the identified unlawful activities, and that less
restrictive measures had proved inadequate.
9. Message Editing Functionality
The Committee has separately considered the material placed on
record by NTA regarding the platform's message-editing
functionality. This material indicated a risk that historical posts and
associated content could be modified after the fact in a manner
capable of facilitating fraudulent claims regarding the prior
publication of examination-related material.
Telegram acknowledged in its reply dated 17th June 2026 that
Telegram's services are not available to users in India. However,
Telegram cannot prevent users from deploying external measures
(such as VPNs) to circumvent blocking measures and Telegram is in
the process of making the "edited" label more prominent to prevent
backdating, and that, being an architectural change, implementation
would take some time. In the specific context of examination fraud
allegations, the temporary disabling of this functionality was
considered a narrowly tailored and precautionary measure, and the
Committee so finds.
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10. Public Order Grounds
The Rajasthan Police Special Operations Group, in its investigation
into the events surrounding the cancelled examination of 3rd May
2026, has reported the recovery of fraudulent examination material
and documented Telegram-based circulation networks.
The Ahmedabad City Cyber Crime Branch, on the eve of the Interim
Direction, arrested members of an inter-State cyber-fraud gang
operating eight Telegram channels pursuant to the same modus
operandi. Documented transactions of approximately ₹1.5 crore
were routed through fraudulent bank accounts, and approximately
one thousand mobile numbers were contacted within a single month.
The arrests followed registration of C.R. No.
111910672600892/2026 at the Cyber Crime Police Station,
Ahmedabad, under Sections 318(4), 319(2), and 54 of the Bharatiya
Nyaya Sanhita read with Section 66D of the Information Technology
Act.
Beyond financial fraud, the operators required candidates to
transmit their previous NEET admit cards and active WhatsApp
numbers as a precondition to receiving any purported "proof,"
thereby converting the operation from a financial fraud into a
personal data exfiltration scheme targeting examination candidates.
Taken together, this material establishes that the misuse of the
Telegram platform in connection with the NEET (UG) 2026
examination is not a single-agency concern. It constitutes a
documented, multi-State law enforcement concern of public-order
character.
11. Acknowledgment by the Platform's Chief Executive
11.1 Public Admission of Scale and Nature of Misuse
On 16th June 2026, Mr. Pavel Durov, Chief Executive Officer of
Telegram, posted publicly on the platform X (formerly Twitter),
under his verified handle @durov: “Over the past few weeks, we
removed hundreds of channels sharing leaked exam materials and
related scams in India. We’re also making the ‘edited’ label more
visible to prevent backdating scams. Telegram is a force for good.
Banning it — even temporarily — is a mistake.”
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This admission directly corroborates the scale and organised
character of the misuse documented in NTA’s successive references.
It also confirms the submission made by NTA at paragraph 4(ii) of
its reference of 21st May 2026 — that the platform’s posture in
respect of offending channels was reactive, after-the-fact removal,
rather than preventive screening. The platform’s own account is one
of removing channels that ought never to have been permitted to
proliferate in the first instance.
11.2 Use of the Terminology “Backdating Scams”
Mr. Durov employs the term “backdating scams” of his own accord.
He does not dispute the existence of such scams, characterise the
underlying concern as fabricated or overstated, or offer any
alternative account of the phenomenon. The category specifically
addressed by the Interim Direction — the post-event fabrication of
pre-examination chat artefacts through the message-editing feature
— is therefore the very category that Telegram’s own Chief
Executive publicly acknowledges.
11.3 Concession that Existing Safeguards Are Inadequate
Mr. Durov’s statement that Telegram is “making the ‘edited’ label
more visible to prevent backdating scams” concedes three matters of
central importance to the present directions:
(a) The “edited” label, in its existing form, lacks sufficient
visibility and requires remediation;
(b) The inadequacy of the label has been actively exploited for
backdating scams — the precise harm the directions address;
and
(c) A unilateral product change is now being made specifically
to address that harm, confirming that the existing design was a
deliberate policy choice by the platform rather than than a
technical necessity — as submitted by NTA at paragraph 5 of
its reference of 21st May 2026 and as detailed in Annexure II
to its reference of 14th June 2026.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

12. Rule 7 Committee Recommendation
The Committee convened on 17th June 2026 and heard
representatives of Telegram, NTA, and the Ministry of Home Affairs.
All parties reiterated their respective submissions and relied upon
material already placed on record. Following detailed deliberation,
the Committee unanimously recommended confirmation of the
Interim Direction dated 16th June 2026.
13. Order
For the reasons recorded herein above, I, Secretary, conclude that:
(i) Substantial material exists on record demonstrating the
continuing misuse of Telegram in connection with examination
fraud and associated unlawful activities;
(ii) Less restrictive alternatives were duly considered and
found inadequate in the prevailing circumstances;
(iii) Invocation of Rule 9 was justified on the facts; and
(iv) NEET is conducted by NTA once in a year and there has
already been an incident where some miscreants exploited the
Telegram platform to spread fake information and to carry
fraudulent activities. Even after engagements with Telegram,
the platform failed to effectively curb such activities or to take
any effective preventive measures, which resulted in
widespread public unrest in the country. A repeat of such lack
of effective remedial measures is likely to further erode the
confidence of students, which can lead to a serious public
order situation in the country and may lead to undermining the
credibility of public institutions like NTA. It can also end up in
violence involving incitement of cognizable offences related to
public order. Hereby, the qualifying cause of public order as
well as incitement to cognizable offences related to public
order are very much satisfied. The Interim Direction
constituted a necessary, proportionate, and time-bound
measure, grounded inter alia in public order.
Accordingly, in exercise of the powers conferred under Section 69A
of the Information Technology Act, 2000, read with the Blocking
Rules, and upon consideration of the unanimous recommendation of
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the Committee constituted under Rule 7, the Interim Direction dated
16th June 2026 is hereby confirmed. All directions contained therein
shall continue to operate in accordance with their terms.
This Order shall take effect immediately. ”
27. A perusal of the Final Order demonstrates that Respondent No. 1
considered the relevant material on record, including, inter alia , the
Petitioners’ written submissions and responses, as well as the
recommendations of I4C / Respondent No. 2 dated 15.06.2026, for
confirming the blocking of public access to Telegram. Thus, the reasons
recorded by Respondent No. 1 in the Impugned Order stand further fortified
by the Final Order.
28. The Petitioners’ contention that the Final Order cannot supplement or
supplant the reasons recorded in the Impugned Order is misconceived. Such
contention is contrary to the scheme of Section 69A of the IT Act read with
the 2009 Rules, which contemplates that, in cases of emergency such as the
present one, an interim blocking direction may be issued upon the
satisfaction of the Secretary of Respondent No. 1, as to the existence of the
conditions specified under Section 69A of the IT Act. Thereafter, a post-
decisional hearing is required to be afforded to the intermediary before a
final order is passed, either confirming or revoking the interim blocking
direction. In such circumstances, the Petitioners’ insistence that detailed
reasons ought to have been supplied in the Impugned Order itself prior to the
grant of an opportunity of hearing is without merit.
29. Further, the Petitioners’ contention that Telegram had complied with
directions for blocking specific content is not determinative for the purposes
of assessing the validity of the directions issued under Section 69A of the IT
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Act. The blocking of individual content was undertaken pursuant to the 2021
Rules, whereas the Impugned Order under Section 69A of the IT Act was
passed upon consideration of the overall architectural features of Telegram,
which rendered it impracticable to prevent misuse of the platform through
the less restrictive measure of blocking individual items of content alone.
30. The Final Order reiterates that the interests of approximately 2.2
million candidates appearing in the NEET UG, 2026 examination were
required to be protected and that any potential disruption to public order had
to be averted. It is in that context that Respondent No. 1 concluded that
temporary blocking of public access to Telegram was necessary for securing
the aforesaid objective.
31. It is, therefore, evident that both the Impugned Order and the Final
Order are founded upon relevant material duly considered by Respondent
No. 1, and that the conclusions recorded therein are supported by the reasons
set out in the said Orders. Accordingly, Issue (i) is answered in the negative,
and it is held that the Orders do not suffer from the vice of non-application
of mind, as alleged by the Petitioners.
Issue Re: (ii)
32. The present issue requires determination of whether the action of
Respondent No. 1 in temporarily blocking public access to Telegram is
sustainable in law. For the purposes of adjudicating the said issue, it is
apposite to consider it under two distinct prongs: first, whether Respondent
No. 1 was legally empowered to issue directions for blocking public access
to Telegram; and secondly, if such power existed, whether the exercise
thereof was disproportionate in the facts and circumstances of the present
case.
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33. For examining the first prong, it is necessary to refer to Section 69A
and Section 2(1)(v) of the IT Act, which are reproduced hereinbelow for
ease of reference:
Section 2(1)(v) of the IT Act
2. Definitions. — (1) In this Act, unless the context otherwise
“
requires,—
(v) ―informationǁ includes [data, message, text,] images, sound,
voice, codes, computer programmes, software and data bases or
micro film or computer generated micro fiche; ”
Section 69A of the IT Act
“ 69A. Power to issue directions for blocking for public access of any
information through any computer resource.–
(1) Where the Central Government or any of its officers specially
authorised by it in this behalf is satisfied that it is necessary or
expedient so to do, in the interest of sovereignty and integrity of
India, defence of India, security of the State, friendly relations with
foreign States or public order or for preventing incitement to the
commission of any cognizable offence relating to above, it may
subject to the provisions of sub-section (2), for reasons to be
recorded in writing, by order, direct any agency of the Government
or intermediary to block for access by the public or cause to be
blocked for access by the public any information generated,
transmitted, received, stored or hosted in any computer resource.
(2) The procedure and safeguards subject to which such blocking for
access by the public may be carried out, shall be such as may be
prescribed.
(3) The intermediary who fails to comply with the direction issued
under sub-section (1) shall be punished with an imprisonment for a
term which may extend to seven years and also be liable to fine ”
34. Section 69A of the IT Act empowers the Central Government, or any
officer specially authorised by it in this behalf, to issue directions for
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blocking public access to any information generated, transmitted, received,
stored, or hosted in any computer resource, where it is satisfied that such
action is necessary or expedient in the interest of the sovereignty and
integrity of India, defence of India, security of the State, friendly relations
with foreign States, public order, or for preventing incitement to the
commission of any cognizable offence relating thereto. Non-compliance
with directions issued under the said provision is punishable with
imprisonment for a term which may extend to seven years, and also with fine.
35. The expression “ information ”, appearing in Section 69A of the IT
Act, is defined under Section 2(1)(v) of the IT Act and includes, inter alia ,
images, sound, voice, codes, computer programmes, software and databases.
The breadth of the said definition indicates that the expression “ information ”
is required to be construed expansively. A restrictive construction, confining
the expression only to individual user accounts, channels, images, posts,
files or messages, would unduly narrow the scope of Section 69A and may
render the provision otiose. The legislative intent, therefore, appears to be to
confer a broad and technologically neutral meaning upon the expression
“ information ”.
36. Further, the term “ computer resource ” is defined under Section
2(1)(k) of the IT Act to mean computer, computer system, computer
network, data, computer data base or software. The expression “ computer ”
used in the definition of “ computer resource ” is defined under Section
2(1)(i) of the IT Act to mean any electronic, magnetic, optical or other high-
speed data processing device or system which performs logical, arithmetic,
and memory functions by manipulations of electronic, magnetic or optical
impulses, and includes all input, output, processing, storage, computer
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software or communication facilities which are connected or related to the
computer in a computer system or computer network.
37. It is the Respondents’ case that, having regard to the definitions of the
expressions “ information ” and “ computer resource ” as used in Section 69A
of the IT Act, the said provision would encompass an application or an
entire platform. An application or platform, in its ordinary and commonly
understood sense, is a computer programme or software designed to perform
specified functions for an end user. In view of the express inclusion of
“ codes ”, “ computer programmes ” and “ software ” within the definition of
“ information ” under Section 2(1)(v) of the IT Act, there is no reason to
exclude an application or platform from the ambit of the said expression.
Further, the definitions of “ computer resource ” and “ computer ” make it
evident that information generated, transmitted, received, stored, or hosted
through such software-based infrastructure falls within the ambit of Section
69A of the IT Act. An application or platform performs logical, arithmetic
and memory functions through electronic, magnetic or optical impulses, and
includes input, output, processing, storage, computer software and
communication facilities connected with a computer system or computer
network. Accordingly, this Court is of the view that Respondent No. 1 was
empowered under Section 69A of the IT Act to issue directions for blocking
public access to Telegram.
38. The next question that arises for consideration is whether the action of
Respondent No. 1 in blocking public access to Telegram can withstand
scrutiny on the touchstone of proportionality, particularly where the stated
object is to prevent misuse of the platform, but the measure also affects the
ability of approximately 150 million Telegram users in India to access the
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platform for lawful and innocuous purposes. The Petitioners contend that the
said action fails to satisfy the proportionality test as enunciated by the
Hon’ble Supreme Court in Anuradha Bhasin ( supra ), wherein it was held
as under:
“ 78. In view of the aforesaid discussion, we may summarise the
requirements of the doctrine of proportionality which must be
followed by the authorities before passing any order intending on
restricting fundamental rights of individuals. In the first stage itself,
the possible goal of such a measure intended at imposing
restrictions must be determined. It ought to be noted that such goal
must be legitimate. However, before settling on the aforesaid
measure, the authorities must assess the existence of any alternative
mechanism in furtherance of the aforesaid goal. The
appropriateness of such a measure depends on its implication upon
the fundamental rights and the necessity of such measure. It is
undeniable from the aforesaid holding that only the least restrictive
measure can be resorted to by the State, taking into consideration
the facts and circumstances. Lastly, since the order has serious
implications on the fundamental rights of the affected parties, the
same should be supported by sufficient material and should be
amenable to judicial review.
79. The degree of restriction and the scope of the same, both
territorially and temporally, must stand in relation to what is
actually necessary to combat an emergent situation.
80. To consider the immediate impact of restrictions upon the
realisation of the fundamental rights, the decision-maker must
prioritise the various factors at stake. Such attribution of relative
importance is what constitutes proportionality. It ought to be noted
that a decision which curtails fundamental rights without
appropriate justification will be classified as disproportionate. The
concept of proportionality requires a restriction to be tailored in
accordance with the territorial extent of the restriction, the stage of
emergency, nature of urgency, duration of such restrictive measure
and nature of such restriction. The triangulation of a restriction
requires the consideration of appropriateness, necessity and the
least restrictive measure before being imposed. ”
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

39. A perusal of the decision of the Hon’ble Supreme Court in Anuradha
Bhasin ( supra ) makes it evident that the doctrine of proportionality requires
the authority imposing restrictions upon fundamental rights to identify the
legitimate objective sought to be achieved by such restriction. The measure
adopted must bear a rational nexus with the said objective and must be
necessary for its attainment. Further, the authority is required to adopt only
the least restrictive measure available in the facts and circumstances of the
case.
40. In the present case, Respondent No. 1 has directed the temporary
blocking of public access to Telegram until 22.06.2026 and the disabling of
the message-editing feature until 30.06.2026, having regard to the NEET
UG, 2026 examination scheduled to be conducted on 21.06.2026. The
underlying object for these measures, as recorded in the Orders, was to avert
any disruption of public order and to prevent the commission of cognizable
offences arising from the dissemination of misleading information regarding
leak of the examination papers and fraudulent activity by miscreants in
relation to the NEET UG, 2026 examination on Telegram.
41. The Petitioners contend that the aforesaid measures of blocking of
access to Telegram until 22.06.2026 and the disabling of the message-
editing feature until 30.06.2026, do not constitute the least restrictive means
for achieving the stated objective and, therefore, fail the test of
proportionality. Per contra , the Respondents submit that, having regard to
the mechanism employed by Telegram and the architecture of the platform,
which enables rapid and widespread dissemination of information, the
impugned measures constitute the least restrictive means available for
achieving the legitimate objective stated in the Orders.
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

42. It is noteworthy that Telegram permits the large-scale addition of
users to channels and groups. The platform architecture of Telegram is
conducive to amplification and mass dissemination of content, enabling
information to reach a substantial number of users within a short span of
time. Consequently, any unlawful content, if circulated on Telegram, is
capable of being amplified rapidly and likely to give rise to a public order
situation.
43. Unlike other conventional platforms, Telegram is entirely cloud-
based, thereby enabling the storage and retrieval of large volumes of
content. Telegram also hosts an extensive bot ecosystem, which facilitates
automated dissemination of content and other activities without human
intervention. Further, the use of usernames in lieu of phone numbers enables
concealment of user identifiers and facilitates the rapid dissemination of
content, including content that may be illicit in nature.
44. Even where a particular channel is identified and, thereafter, disabled
pursuant to complaints made by the concerned authorities, the subscriber
base of such channel does not necessarily cease to exist, as Telegram’s
architecture permits the rapid creation of mirror channels under different
names or identifiers, to which existing subscribers may be redirected. As a
result, illicit activity may resume within a short period notwithstanding
takedown action against the original channel. Further, Telegram permits
messages, including files, to be edited at a later point in time. Such
functionality may be employed to disseminate misinformation by editing
messages sent prior in time by replacing the attachment to give impression
that the examination paper was leaked prior to the examination even though
such editing takes place after conclusion of the examination. Accordingly,
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

any subsequent editing of messages relating to NEET UG, 2026 may
mislead general public and, consequently, give rise to a potential public
order situation.
45. The Orders expressly record that entity-specific interventions,
including the reporting and removal of channels, groups, bots, and accounts,
were repeatedly found to be ineffective and inadequate. Further, the
audience-migration mechanisms enable operators to rapidly reconstitute
networks after enforcement action was taken by the concerned authorities. It
is clearly observed in the Orders that despite corrective measures having
been sought in relation to various misuses of the Telegram platform, fresh
material, including reports received from Respondent Nos. 2 and 3,
disclosed the continued occurrence of illicit activities by unlawful entities
notwithstanding prior interventions. Therefore, it is evident that narrower
measures, including the takedown of specific bots and channels, were
ineffective having regard to the particular nature and architecture of the
Telegram platform.
46. In the present case, the NEET UG, 2026 examination is scheduled to
be conducted on 21.06.2026. The temporary blocking of Telegram under the
Orders is operative only until 22.06.2026, while the disabling of the
message-editing feature is confined to the period until 30.06.2026. The
limited temporal scope of these measures demonstrates that they are
narrowly tailored and confined to the period strictly necessary for securing
the stated objective. Applying the parameters laid down in Anuradha
Bhasin ( supra ), this Court is satisfied that the requirements of
proportionality stand fulfilled, namely: (i) identification of a legitimate
objective; (ii) existence of a rational nexus between the objective and the
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Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03

measure adopted; (iii) necessity of the measure in the facts and
circumstances of the case; and (iv) adoption of the least restrictive measure
available.
47. Accordingly, the measures adopted by Respondent No. 1 under the
Orders constitute the least restrictive measure for achieving the stated
objective. Accordingly, the action of Respondent No. 1 in temporarily
blocking public access to Telegram cannot be held to be disproportionate.
Issue (ii) is, therefore, answered in the affirmative.
48. In view of foregoing analysis, the present Petition, along with pending
Application, is hereby dismissed.
TEJAS KARIA, J
(VACATION JUDGE)
JUNE 19, 2026
St /N/ sms/ap
Signature Not Verified
W.P.(C) 8259/2026 Page 39 of 39
Signed By:NEELAM
SHARMA
Signing Date:19.06.2026
12:42:03