Delhi High Court: In a writ petition instituted under Articles 226 and 227 of the Constitution challenging an interim order dated 16 June 2026 (impugned order) passed by Respondent 1, Union of India through Ministry of Electronics and Information Technology (MeitY), under Section 69-A, Information Technology Act, 2000 (IT Act) directing the temporary blocking of the Telegram platform throughout India and required Telegram to disable its message-editing feature, the Single Judge Bench of Tejas Karia*, J., affirmed the impugned order and held that:
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The interim and final orders did not suffer from non-application of mind.
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The expression “information” under Section 2(1)(v), IT Act is broad enough to include an entire software platform or application.
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The Government was empowered under Section 69-A, IT Act to issue directions for blocking public access to Telegram, where circumstances warrant such action.
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The temporary blocking of Telegram and the disabling of its message-editing feature were proportionate, necessary and legally sustainable measures aimed at protecting the integrity of the National Eligibility-cum-Entrance Test (Undergraduate), 2026 (NEET-UG 2026) examination and preserving public order.
Factual Matrix
The National Testing Agency (NTA) informed MeitY on 21 May 2026 about the alleged misuse of Telegram in relation to the NEET-UG 2026. According to the communication, Telegram channels, groups and bots were being used to circulate purported examination papers, fraudulent claims concerning examination leaks and misleading information connected with NEET-UG 2026. In response, MeitY issued a notice on 1 June 2026 and convened a meeting on 3 June 2026 involving Telegram and NTA. Telegram acknowledged the notice and submitted a detailed written response before the meeting.
Telegram maintained that it prohibited examination fraud and operated extensive moderation systems involving artificial intelligence tools, machine-learning mechanisms, human review processes, reporting systems and enforcement actions. Following the meeting, Telegram sent a communication summarising the discussions, while MeitY issued minutes of the meeting on 5 June 2026. Telegram disputed portions of those minutes and submitted clarifications.
On 9 June 2026, MeitY provided Telegram with a list of channels, bots and accounts allegedly connected with examination-related fraud. Telegram informed the authorities that the identified URLs had been taken down. Despite these actions, the authorities remained concerned that unlawful entities were reappearing through backup channels, mirror channels and automated systems.
The MeitY, by way of impugned order under Section 69-A IT Act, issued following direction:
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“Telegram and its associated URLs to be blocked across India within one hour of the receipt of the Impugned Order, till 22 June 2026;
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Telegram to disable the message editing feature till 30 June 2026;
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The Department of Telecommunication to instruct application stores and internet service providers to block / disable access to Telegram till 22 June 2026; and
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The Designated Officer to place the matter before the Committee under Rule 7 of the Information Technology (Procedure and 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.”
Also Read: MeitY Advisory to Social Media Platforms on Unlawful Online Content: Compliance Under IT Act & Rules
Issues for Determination
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Whether the impugned order passed by Respondent 1 vitiated by non-application of mind?
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Whether the action of Respondent 1 in temporarily blocking public access to entire Telegram platform satisfies the requirement of proportionality?
Analysis and Findings
Issue I: Non-Application of Mind
The Court rejected the argument that the impugned order was merely a reproduction of statutory language. After examining the order in detail, the Court found that it recorded satisfaction regarding the misuse of Telegram for dissemination of examination-related misinformation, circulation of purported examination papers and other fraudulent and unlawful activities likely to have serious implications for public order in the country. The Court observed that the order established a direct connection between the material before the authority and the conclusions reached.
The Court emphasised 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” as they demonstrate the nexus between facts and conclusions. However, given the emergency character of the proceedings under Section 69-A, the Court held that the reasons recorded in the interim order were adequate. Since Respondent 1 had strictly followed the procedural steps as required under Section 69-A, IT Act, therefore, the challenge to the impugned order on the ground non-communication of reasons cannot be sustained. Accordingly, the Court held that the objections founded on alleged non-application of mind and inadequacy of opportunity of hearing failed.
Relying on the detailed final order, which considered extensive material including reports from NTA and Indian Cybercrime Coordination Centre (I4C), Telegram’s written submissions and oral arguments before the Committee, the Court observed that the final order reinforced and elaborated upon the reasoning contained in the interim order. Since the statutory framework itself envisaged an interim order followed by a post-decisional hearing and final determination, the petitioners could not insist that every detailed reason be contained in the emergency order itself.
The Court also rejected the submission that Telegram’s compliance with content takedown requests rendered the blocking order invalid. Compliance with obligations under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (2021 Rules), did not address the broader concerns regarding the platform’s architecture and the recurring ineffectiveness of targeted enforcement.
Ultimately, the Court held that both orders were based on relevant material and reflected a proper application of mind. Accordingly, the Court answered Issue I against the petitioners.
Issue II: Legality and Proportionality of Blocking Telegram
The Court examined whether Section 69-A empowered the Government to block an entire platform. It noted that ““Section 69-A, IT Act empowers the Central Government, or any officer specially authorised by it in this behalf, to issue directions for 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.”
Referring to the definitions of “information” and “computer resource” under the IT Act, the Court observed that “information” expressly includes codes, computer programmes, software and databases. Since an application or platform is fundamentally composed of software, code and databases operating through computer resources, it falls within the statutory definition. Therefore, the Court held that Section 69-A authorises blocking not merely of individual messages or channels but also of an application or platform where circumstances justify such action. Accordingly, the Court opined that Respondent 1 was empowered under Section 69-A, IT Act to issue directions for blocking public access to Telegram.
Turning to proportionality, the Court applied the principles laid down in Anuradha Bhasin v. Union of India, (2020) 3 SCC 637, and noted that the Government had identified a legitimate objective, namely protection of examination integrity, prevention of fraud and maintenance of public order in connection with NEET-UG 2026. The Court accepted that Telegram’s design facilitated rapid and large-scale dissemination of information through channels, groups, bots and file-sharing mechanisms. Its cloud-based infrastructure and username-based operations enabled unlawful actors to evade enforcement measures and quickly rebuild networks after takedowns.
The Court observed that mirror channels, reserve channels and audience migration mechanisms had repeatedly undermined entity-specific interventions. Evidence had demonstrated that despite numerous takedowns, unlawful networks continued to reappear. Consequently, the Court accepted the Government’s reasoning that narrower measures had proved ineffective. It also regarded the message-editing feature as particularly significant because it could be exploited to create the false impression that examination papers had been leaked before the examination. The Court took note of Telegram CEO’s public acknowledgment of both the scale of misuse and the inadequacy of the “edited” label and treated it as a concession. Such misuse had the potential to undermine confidence in the examination process and trigger public unrest.
The Court placed considerable weight on the limited duration of the restrictions. The platform-wide block was to remain operative only until 22 June 2026, immediately after the re-examination, while the disabling of message editing was confined to 30 June 2026. The Court opined that the measures were narrowly tailored to the examination period and did not constitute an indefinite restriction.
Considering the urgency of the situation, the recurring ineffectiveness of targeted enforcement and the temporary nature of the restrictions, the Court held 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 measure adopted;
(iii) necessity of the measure in the facts and circumstances of the case; and
(iv) adoption of the least restrictive measure available.”
Accordingly, the Court answered Issue II in favour of the respondents.
Decision
The Court held that the interim and final orders issued under Section 69-A, IT Act were supported by relevant material, complied with the statutory procedure and satisfied the doctrine of proportionality. Accordingly, the writ petition and all pending applications were dismissed.
[Telegram FZ LLC v. Union of India, W.P.(C) 8259/2026, decided on 19-6-2026]
*Judgment authored by Justice Tejas Karia
Advocates who appeared in this case:
Mr. Dhruv Mehta, Senior Advocate with Mr. Madhav Khosla, Mr. Abhi Udai Singh Gautam, Ms. Roshni Ojha and Mr. Keith Verghese, Advs., Counsel for the Petitioner
Mr. R. Venkatramani, Attorney General for India, 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., Counsel for the Respondent 1 and 2
Mr. Sanjay Khanna, Standing Counsel along with Ms. Pragya Bhushan, Ms. Jaya Choudhary & Mr. Saurabh Pandey, Advs., Counsel for the Respondent 3
