Introduction
The Ministry of Electronics and Information Technology (MeitY) on 16 June 2026 issued two directions related to the Telegram messaging platform under the recommendations of the National Testing Agency (NTA).[1]
- The first was a temporary ban on Telegram that was carried out across the country. This restriction was valid till 22 June 2026, i.e., one day after the day of the re-examination of NEET (UG) 2026, which was held on 21 June 2026.
- The second direction is a more restricted one that lasts for a longer time. It mandates Telegram to remove the ability to edit messages for users in India until 30 June 2026 so that users cannot edit messages that have already been posted.
The NTA said that these measures are being implemented due to the increasing use of Telegram by organized groups allegedly involved in examination-related fraud.[2] There were several channels, with names like ‘PAPER LEAKED NEET’ and ‘Re-NEET 2026,’ that were allegedly promoting and selling leaked examination papers. Subsequent investigations indicated that such materials had been manufactured and designed to mislead students taking the test and the examination papers were not actually leaked.
The authorities also noted that some of the users were using the editing feature of the Telegram message to edit previous messages after the examination had been completed, which could give the impression that the exam questions were leaked beforehand and thus fake evidence of a paper leak.[3] Further, the NTA has said that the restrictions are a last-resort measure and that it has tried to tackle the problem by targeted takedowns on the channel level, which had not worked.
These guidelines signal an unprecedented regulatory measure intended to safeguard the integrity of a national exam and pose serious legal challenges regarding digital governance, intermediary liability and the rights of the users.
Statutory Basis: Section 69a Of The Information Technology Act, 2000
In the present case, the government’s action is based on Section 69A of the Information Technology Act, 2000.[4] This provision empowers the Central Government to direct an intermediary, internet service provider, or other appropriate party to block access to information made available through a computer resource when the Central Government is satisfied that such action is necessary or expedient in the interests of the sovereignty, integrity, defense, security, friendly relations with foreign states, public order, or for preventing incitement to the commission of a cognizable offence in India.
Interestingly, these grounds are similar to those that restrict freedom of speech and expression under Article 19(2) of the Indian Constitution.[5] The design of the legislation is deliberate, and any limitation on online communication is connected to a limitation on freedom of expression as recognized in the Constitution.
In the present case, the government has been basing itself mainly on the ground of ‘public order.’[6] The National Testing Agency has given reasons that some Telegram channels were being misused by organized fraud groups to mislead the candidates who were appearing for the NEET (UG) re-examination.[7] These channels allegedly spread rumors about having leaked examination papers and then took money from students and their families for fake papers.
The authorities have also stated that these practices posed a risk to the integrity and credibility of a national public examination that is overseen by a statutory body.[8] In this regard, the temporary blockage of the Telegram application and the suspension of the editing of messages was not only meant to reduce the spread of fake information but also to maintain public trust in the examination process and to prevent large-scale examination-related fraud.
Telegram As a Data Fiduciary Operating In India
The restrictions imposed on Telegram are under the Information Technology Act, 2000, but they also give rise to important questions under the Digital Personal Data Protection Act, 2023[9] and the Digital Personal Data Protection Rules, 2025.[10]
Telegram qualifies as a Data Fiduciary for its massive Indian user base, as it gathers and processes data including users’ phone numbers, message data, and some generated content.[11] The foreign incorporation of the platform does not mean that it is not covered by Indian data protection law. The DPDP Act applies to processing activities even outside of India, provided they relate to providing services to persons in India.[12] This means that a temporary ban on Telegram does not affect Telegram’s obligations under the DPDP framework.
The platform shall continue to ensure reasonable security measures to safeguard personal data already held by the platform.[13] Similarly, if a data breach takes place during the time of limited access, Telegram is also required to notify the Data Protection Board and affected users.[14] Furthermore, the restriction also does not apply to the rights of Indian users for access, correction, or erasure of their personal data.[15]
Intermediary Licensing and Safe Harbour Framework
The legal regime for Telegram in India is largely based on the Information Technology Act, 2000 instead of the telecommunications licensing regime. Telegram is an ‘intermediary’[16] since it is a platform that enables the hosting and transmission of user-generated content. One of the key principles of this regulation is the protection afforded by Section 79 of the IT Act, which provides a general safe harbour for intermediaries from liability for third-party information, provided they act as a neutral information service and meet the statutory requirements.[17]
But this protection is subject to the condition that the intermediary must remove or disable access to the content promptly when it has ‘actual knowledge’ of the illegal content pursuant to a valid court order or a government notification.[18]
In the present case, the National Testing Agency has said it had asked for the deletion of certain Telegram channels, which were spreading fake claims about leaked NEET exam papers.[19] The authorities said these channel-level interventions failed to be effective hence the broader restriction was urgently required.[20] The sequence is of legal importance, as it indicates that the company had tried to implement targeted enforcement measures prior to seeking a blanket restriction at the platform level, and could be relevant to whether the company fulfilled its intermediary obligations and thus retained safe harbour protection.
Intellectual Property Rights Dimension
Apart from the NEET re-examination controversy, Telegram has been subjected to a substantial amount of IP enforcement action in India over the years. The platform has been accused of hosting pirated movies, TV shows, books, software, and other copyrighted material.[21]
The Ministry of Information and Broadcasting issued instructions to Telegram in March 2026 to remove over 3,100 channels that were allegedly facilitating access to more than 1,100 instances of pirated content.[22] The order also mandated the platform’s preservation of pertinent evidence, requiring that it not be destroyed or altered.[23]
The Indian courts have also been stringent in dealing with violations of intellectual property rights on the platform. In one copyright infringement matter, Telegram was ordered to reveal the identities of those who manage channels used for illegal distribution of copyrighted content.[24] The court rejected Telegram’s contention that such disclosure would breach its privacy policy, reiterating the principle that valid judicial orders under Indian law prevail over privacy commitments made by platforms.[25]
Likewise, there is another, related, intellectual property and confidentiality issue in the current NEET controversy. NTA-prepared examination papers are confidential and unpublished works subject to protection under the Copyright Act, 1957.[26] The use of genuine examination papers that have been leaked and circulated prior to the examination may constitute copyright infringement, involving the unauthorised reproduction and dissemination of protected material.[27] Concurrently, such conduct would also expose the actor to liability under the Public Examinations (Prevention of Unfair Means) Act, 2024, dedicated legislation against question paper leakages and the use of electronic media for examination malpractice.[28]
The NTA, however, has claimed that there was no leak of any authentic NEET paper, and that the channels involved were merely circulating fake papers to mislead students.[29] If this position is correct, the conduct is more accurately characterized as fraud and cheating under the Bharatiya Nyaya Sanhita, 2023[30] rather than a conventional copyright violation. The intellectual property dimension would apply only if it is later determined that there has been unlawful reproduction or dissemination of authentic confidential examination material on the platform.
Synthesis and Conclusion
The Telegram restriction of June 2026 is not merely a ban on the platform but a comprehensive regulatory action in response to the concerns raised about the NEET (UG) re-examination. The Ministry of Electronics and Information Technology invoked Section 69A of the Information Technology Act, 2000,[31] and restricted access to Telegram and its message-editing feature, on the recommendation of the National Testing Agency, to maintain public order and prevent organized fraud against examination candidates.
Furthermore, the restriction was issued under the IT Act but not under the Digital Personal Data Protection Act, 2023.[32] The platform, used by millions of Indians, continued to be a Data Fiduciary and remained accountable for safeguarding personal data, reporting data breaches, and meeting legitimate requests for disclosure of data.
In addition, authorities reportedly pursued channel-level interventions before resorting to a platform-wide restriction, a sequence that may be relevant when considering the proportionality of the government’s measures and Telegram’s entitlement to safe harbour protection under Section 79 of the IT Act.[33] The issue also overlaps with intellectual property and examination-security concerns. Ultimately, the episode highlights the growing interconnectedness of platform regulation, data security, intermediary liability, examination integrity, and digital governance in India’s evolving legal landscape.
In conclusion, the Telegram restriction in June 2026 is a significant case study in India’s digital governance landscape, underscoring the need to strike a balance between safeguarding fundamental rights, holding platforms accountable, and protecting the public interest as new technologies and challenges arise.
Footnotes :
[1]Press Release, Ministry of Electronics & Information Technology, Gov’t of India, MeitY Issues Directions Concerning Telegram Messaging Platform (June 16, 2026) (on file with NTA); see also Order, Nat’l Testing Agency, Recommendation for Temporary Restriction of Telegram Pending NEET (UG) 2026 Re-Examination (June 16, 2026).
[2]Nat’l Testing Agency, Press Statement on NEET (UG) 2026 Re-Examination Security Measures (June 16, 2026).
[3]Id.
[4]Information Technology Act, No. 21 of 2000, § 69A, INDIA CODE (2000).
[5]INDIA CONST. art. 19, cl. 2; see also Shreya Singhal v. Union of India, (2015) 5 S.C.C. 1 (India) (upholding the constitutional validity of § 69A as appropriately tethered to the Article 19(2) grounds).
[6]Information Technology Act § 69A(1).
[7]Nat’l Testing Agency, supra note 2.
[8]Id.
[9]Digital Personal Data Protection Act, No. 22 of 2023, INDIA CODE (2023) [hereinafter DPDP Act].
[10]Digital Personal Data Protection Rules, 2025, Gazette of India, pt. II, § 3(i) (Nov. 13, 2025) [hereinafter DPDP Rules].
[11]DPDP Act § 2(i) (defining ‘Data Fiduciary’ as any person who alone or in conjunction with other persons determines the purpose and means of processing of personal data).
[12]DPDP Act § 3(b).
[13]DPDP Rules, supra note 10, r. 6.
[14]DPDP Rules, supra note 10, r. 7.
[15]DPDP Act §§ 11–13.
[16]Information Technology Act § 2(1)(w).
[17]Information Technology Act § 79.
[18]Information Technology Act § 79(3)(b); see also Shreya Singhal, (2015) 5 S.C.C. 1 (India) (reading down § 79(3)(b) to require actual knowledge in the form of a court order or government notification under § 69A, rather than a private complaint).
[19]Nat’l Testing Agency, supra note 2.
[20]Id.
[21]Press Release, Ministry of Info. & Broad., Gov’t of India, Directions to Telegram for Removal of Pirated Content Channels (Mar. 2026).
[23]Id.
[24]See, e.g., John Doe v. Telegram FZ-LLC, [Delhi High Court, copyright infringement proceedings] (order directing disclosure of channel administrator details) (on file with author).
[25]Id.
[26]Copyright Act, No. 14 of 1957, § 13, INDIA CODE (1957).
[27]Copyright Act § 51 (defining infringement to include unauthorized reproduction of a literary work without license of the owner of the copyright).
[28]Public Examinations (Prevention of Unfair Means) Act, No. 6 of 2024, § 3, INDIA CODE (2024).
[29]Nat’l Testing Agency, supra note 2.
[30]Bharatiya Nyaya Sanhita, No. 45 of 2023, §§ 318–319, INDIA CODE (2023) (replacing the erstwhile Indian Penal Code §§ 415, 420 provisions on cheating and fraud).
[31]Information Technology Act § 69A.
[32]DPDP Act, supra note 9.
[33]Information Technology Act § 79.
