Telegram vs. Union of India: How the Delhi High Court Upheld the Platform-Wide Block Under Section 69A of the IT Act

We typically go to great lengths to prevent harm from others. Usually we do everything we can to avoid harming others.

The Delhi High Court on June 19, 2026, dismissed a writ petition by Telegram FZ LLC that challenged the blocking of the messaging app in India by the government, giving a significant decision on internet governance, intermediary liability, and the ambit of Section 69A of the Information Technology Act, 2000. The case was triggered by the alleged misuse of Telegram by the fraudsters spreading fake leaked papers and spreading misinformation regarding the National Testing Agency (NTA) conducted NEET UG-2026 medical entrance examination.

This judgment is one of the most thorough judicial review of the scope of the government's power to block an entire platform, not just specific URLs, channels, or content, under Section 69A and of the concept of proportionality to such broad restrictions on the internet.

The allegations of background information regarding NEET UG 2026 Paper Leak have been surfacing. NEET UG 2026 Paper Leak Allegations

The incident had its roots in a letter sent by the NTA to the Ministry of Electronics and Information Technology (MeitY) regarding the Telegram channels and bots said to be engaged in NEET UG 2026 paper-leak fraud on May 21, 2026. This was followed by a regulatory procedure:

On 3rd June 2026, MeitY issued a notice along with a meet with NTA and Telegram.
MeitY provided a list of more than 1,300 URLs associated with fraudulent activities related to the NEETs, Telegram removed about 900 of these.
On June 16, 2026, MeitY issued an interim blocking order, instructing the blocking of Telegram throughout India, effective from June 22, 2026, and its message-editing function, which is scheduled to be disabled from June 30, 2026.
The Rule 7 Committee issued a Final Order, confirming the block, on June 17, 2026, after hearing allegations of ongoing circulation of "backup channels and bots" of content.

Both the orders were challenged by the Telegram before the Delhi High Court under Article 226 & 227 of the Constitution.

Telegram's Core Arguments

Telegram's senior advocate, Dhruv Mehta, said:

There is a lack of adequate reasoning in the blocking order and it has not performed a genuine proportionality assessment considering the impact on over 150 million Indian users.
Blocking of certain "information" is only allowed under section 69A, not of a whole intermediary platform – a platform ban was ultra vires the provision.
There were less-restrictive options, as Telegram had already complied with takedown requests for hundreds of URLs.
The Supreme Court in Anuradha Bhasin v. Union of India (2020) 3 SCC 637, relied upon the principle that the least restrictive measure must be adopted to restrict fundamental rights.
The Government's arguments for the Block were sound.

Content-by-content takedowns were ineffective because of Telegram's architecture, the Solicitor General and Attorney General said, including cloud storage, anonymous user names, automated bots and being able to quickly launch "mirror channels. They noted that despite the repeated attempts they have made to take down these fraudulent channels related to NEETs, new ones have surfaced using new near-burner phone numbers and new burner accounts.

The real meaning of Section 69A of the IT Act

To understand this judgment, one has to grasp the essence of the statute. Section 69A gives the Central Government the powers to prevent the access of public records of information to the public where it is necessary to do so in the interests of the sovereignty, security, public order or to prevent incitement to a cognizable offence. The Court quoted the relevant text which states that "on being satisfied that such action is necessary, the Government, by order, may direct any agency of the Government or any intermediary to block for access by the public or cause to be blocked for access by the public information generated, transmitted, received, stored or hosted in any computer resource, for reasons to be recorded in writing.

The word "information" was the crucial interpretive issue in this case. Telegram said that it was about individual pieces of information: a post, a file, a channel — not an entire app. The government contended that the definition was much more expansive.

The Court's Reasoning: What does “Information” Mean when an Entire App is Involved?

This is the most important portion of the ruling. The Court considered the meaning of the word “information” as defined in Section 2(1)(v) of the IT Act, which defines information as data, messages, text, images, sound, voice, codes, computer programs, software and databases. The Court explained that an app is a collection of code, software and databases – excluding platforms would be a “fiction.”

The Court said it found a restrictive construction that would limit the meaning of Section 69A to individual user accounts/accounts, channels, images, posts, files or messages "unduly narrow" and could make the provision "otiose". It also concluded that an application "perform[s] logical, arithmetic and memory functions by electronic, magnetic or optical impulses" is clearly covered by the definition of a "computer resource" and "computer" under the Act. The Court, on this basis, has concluded that MeitY has the legal authority to block the entire Telegram platform and not any particular text on the platform.

Applying Proportionality Test put forward by Anuradha Bhasin

The Court found the power was there, and now considered if it was proportionate. It used the four-part proportionality analysis set out by Anuradha Bhasin: (1) the existence of a legitimate goal; (2) a rational link between the measure and the goal; (3) necessity of the measure; and (4) the use of the least restrictive means available.

The Court concluded that Telegram's architecture, which includes its bot system, mirror-channels, and anonymous user names, was "structurally impossible" to be narrowed to channel-specific takedowns. Given that the fraudulent NEET content continued to show up "through new channels, backup channels, rotated handles, and burner accounts," it observed that "takedowns alone will not be effective.

Final Verdict

The Delhi High Court said that:

The impugned Order and the Final Order were not vitiated by non-application of mind as both had adequate reasoning in the emergency situation and the Final Order, passed after the hearing, could support the reasoning in the interim order.
Due to the specific circumstances of the imminent national examination to the system, the platform-wide block was found to be the least restrictive effective measure available and thus passed the proportionality test.

Therefore, the Court quashed the writ petition and also the Final Order passed by Section 69A.