A single-judge bench of Justice Tejas Karia, functioning as vacation judge, examined two key questions. The first was whether the government's order suffered from non-application of mind, and the second was whether the blocking of Telegram met the constitutional test of proportionality. The latter issue depended on a more fundamental question regarding statutory interpretation: whether Section 69A of the Information Technology Act empowers the government to block an entire platform or only specific content. The court ruled against Telegram on both issues.
The original NEET-UG 2026 examination, conducted on May 3, was cancelled on May 12 after similarities emerged between a leaked guess paper and the actual question paper. The controversy triggered a Central Bureau of Investigation inquiry, leading to the arrest of 13 individuals.
As preparations for the re-examination intensified, several Telegram channels, including those named "Private Mafia" and "PAPER LEAKED NEET", allegedly sold fake question papers for amounts reaching ₹10 lakh. According to government submissions made earlier in the week, channel administrators exploited Telegram's message-editing feature, which allows content modification without altering the original timestamp, to create fabricated evidence of question paper leaks after examinations had concluded. Authorities argued that channel-specific takedowns repeatedly failed because deleted channels quickly resurfaced through mirror channels, prompting the government to seek a complete temporary shutdown of the platform before the re-examination.
On June 16, the government issued an interim order under Section 69A of the Information Technology Act directing internet service providers to block Telegram and associated web addresses throughout India until June 22. The order also instructed the platform to disable its message-editing feature until June 30. Following a hearing before a committee constituted under Rule 7 of the Information Technology Blocking Rules on June 17, the Secretary of the Ministry of Electronics and Information Technology passed a final order on June 18 confirming the interim directions. That final order became the subject of Telegram's challenge before the High Court.
Relying on the Supreme Court's judgment in Anuradha Bhasin versus Union of India, Telegram argued that only the least restrictive measure was permissible and that a platform-wide ban disregarded the rights of more than 15 crore Indian users who had no connection with examination fraud.
Solicitor General Tushar Mehta and Additional Solicitor General Chetan Sharma, representing the government, argued that Telegram's cloud-based architecture, large public broadcast channels, automated bot ecosystem, anonymous usernames and message-editing function rendered content-specific enforcement ineffective. They informed the court that the Indian Cybercrime Coordination Centre had sought corrective measures from Telegram on at least 35 occasions since October 2024. They also highlighted the existence of a channel named "NEET Mafia", which had nearly 18,000 subscribers and continued to re-emerge through mirror channels that redirected existing members.
Attorney General R. Venkatramani argued that a profit-oriented commercial platform could not selectively invoke the doctrine of proportionality to resist legitimate preventive actions undertaken by the State in the larger public interest.
Rejecting Telegram's contention that Section 69A authorises only content-specific blocking, the court accepted the government's interpretation that the definition of "information" under the statute, which explicitly includes codes, computer programmes, software and databases, is broad enough to encompass an entire application. The court observed that a digital application itself represents a compilation of software and code and held that there was no reason to exclude a platform from the scope of the provision. Accordingly, it ruled that the government possessed the authority under Section 69A of the Information Technology Act to block public access to Telegram in its entirety.
Addressing the issue of proportionality, the court applied the four-pronged test laid down by the Supreme Court in Anuradha Bhasin, namely legitimate objective, rational connection, necessity and adoption of the least restrictive measure. The court found that all four requirements had been satisfied.
The judgment observed that Telegram's architecture facilitates rapid amplification and mass dissemination of information, allowing unlawful content to reach a vast number of users within a short period. Consequently, the court noted that any illegal material circulated on the platform had the potential to create a public order situation.
The court further found that content-specific removals had repeatedly failed because deleted channels reappeared through backup channels, changed identifiers and disposable accounts. Under such circumstances, it held that a temporary platform-wide block until June 22, coupled with restrictions on the editing feature until June 30, constituted the least restrictive measure available considering the urgency and proximity of the re-examination.
On Telegram's allegation of non-application of mind, the court ruled that the reasoning contained in the interim order, when read alongside the detailed findings incorporated in the final order following a hearing, established a direct and substantial connection between the restrictions imposed and the grounds relied upon by the government.
The final order also referred to a June 16 post by Telegram founder and chief executive Pavel Durov on the social media platform X. In the post, Durov stated that the company had removed hundreds of channels sharing leaked examination material and was making the "edited" label more prominent to prevent timestamp manipulation. The committee viewed the statement as corroboration of the scale of abuse alleged by the government and as an acknowledgment that the existing warning mechanism had been inadequate.
The High Court rejected Telegram's argument that the detailed reasons contained in the final order could not compensate for alleged deficiencies in the interim order. It held that the two-stage procedure consisting of an emergency interim direction followed by a post-decisional hearing and a reasoned final order was precisely the mechanism contemplated under Section 69A and the Information Technology Blocking Rules, 2009.
The ruling marks a major judicial endorsement of the government's emergency powers under the Information Technology Act and underscores the increasing legal scrutiny of digital platforms amid concerns over examination security and the rapid spread of unlawful content affecting public order and the interests of millions of students.
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