Delhi HC upholds Telegram ban before NEET UG 2026 re-exam, cites proportionality
Synopsis
Key Takeaways
The Delhi High Court on Friday, 19 June 2025, upheld the Centre's decision to temporarily suspend Telegram's services across India ahead of the NEET (UG) 2026 re-examination, ruling that the government had strictly followed the procedure prescribed under law and that the restrictions satisfied the constitutional test of proportionality. The judgment comes days before the re-examination, scheduled for 21 June, for over 22 lakh candidates.
What the Court Ruled
A single-judge Bench of Justice Tejas Karia dismissed a petition filed by Telegram FZ LLC challenging the Ministry of Electronics and Information Technology (MeitY) blocking order. The court held that the temporary suspension of the messaging platform until 22 June and the disabling of its message-editing feature until 30 June were justified given the circumstances surrounding the nationwide medical entrance examination.
'Given the emergency nature of the Impugned Order, the reasons supplied in arriving at the decision were sufficient. As Respondent No. 1 (Union government) 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,' the court said.
The Proportionality Test
On the issue of proportionality, Justice Karia held that the four parameters laid down by the Supreme Court in the landmark Anuradha Bhasin judgment were fully satisfied — namely, identification of a legitimate objective; existence of a rational nexus between the objective and the measure adopted; necessity of the measure in the facts and circumstances; and adoption of the least restrictive measure available.
The court added that the measures constituted 'the least restrictive measure' available for achieving the stated objective and therefore could not be termed disproportionate.
Why Platform-Wide Action Was Deemed Necessary
Rejecting Telegram's contention that only specific channels or accounts should have been targeted, the court found that the platform's architecture enabled rapid and large-scale dissemination of content, making channel-specific takedowns ineffective.
'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,' the judgment observed.
The court further noted that Telegram's cloud-based structure, extensive bot ecosystem, and ability to create mirror channels allowed unlawful actors to quickly reconstitute networks even after enforcement action. It found that narrower measures — including the takedown of specific bots and channels — had proven ineffective given the particular nature and architecture of the platform.
Scope of Section 69A: Can an Entire Platform Be Blocked?
The court also rejected Telegram's argument that Section 69A of the Information Technology Act empowered the government only to block specific content and not an entire platform. Holding that the term 'information' under the IT Act carries a broad meaning, Justice Karia ruled that an application or platform falls within its ambit as it comprises 'codes', 'computer programmes', and 'software'.
'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,' the judgment stated.
Background: NEET Paper Leak and the Blocking Order
The restrictions were imposed under Section 69A following recommendations by the National Testing Agency (NTA) and the Ministry of Home Affairs. According to the Centre, the NTA had identified several Telegram channels allegedly involved in selling purported NEET question papers and facilitating examination-related scams. The government argued that content-specific takedowns were ineffective because channels and bots could be recreated within minutes.
The NEET (UG) 2026 re-examination is scheduled for 21 June for over 22 lakh candidates, following allegations of question paper leaks in the original examination conducted on 3 May. The court's ruling effectively keeps the platform-wide restrictions in place through the examination date.