On June 2, 2026, Estonia's Riigikogu adopted amendments to its Emergency Situations and National Defense Act by 64 votes to 14, extending the power to restrict press reporting during wartime from the prime minister and ministers to the Police and Border Guard Board, the Internal Security Service, the Defense Forces, and the TTJA telecoms regulator. The Estonian Media Association, excluded from the drafting, announced it will challenge the law before the president and the chancellor of justice, warning that the broad wording lets a "fairly low-level official" suppress "virtually any information" by interpretation.
Estonia's fight is, on its face, a European one. But the structural problem it exposes — discretionary power to control information without a duty to disclose how that power is used — is the same flaw that runs through India's content-takedown architecture. The lesson worth importing is not Estonia's restriction; it is the transparency machinery that should accompany any such power, and which India still refuses to build.
The strongest case for the restriction
The Estonian government's argument deserves a fair hearing. A state facing the credible threat of invasion has a legitimate interest in preventing the real-time publication of troop movements, the location of military units, or details of critical infrastructure — exactly the operational information ERR reports the bill is meant to cover. Estonia also added oversight: the chancellor of justice gains expanded power to review whether emergency declarations comply with the constitution. This is not Russia's information regime. It is a democracy trying to draw a wartime line.
The problem is the gap between stated intent and statutory text. When the operative standard is whether publication "threatens public order, state security or the provision of military defense," and the deciding official sits several rungs below the cabinet, the limiting principle lives entirely in interpretation. That is the Media Association's point, and it is a sound one: a power defined by its outer edge, not its core, will be used to its edge.
India built the edge and removed the disclosure
India offers a fully developed version of what unaccountable information control looks like. Under Section 69A of the IT Act, 2000, the government can order intermediaries to block content on grounds including the sovereignty and security of the state. The 2009 Blocking Rules layer in procedural safeguards — reasoned orders, notice, a review committee — but Rule 16 makes the proceedings confidential, so the orders almost never see daylight.
The newer mechanism is worse. On September 24, 2025, in X Corp v. Union of India (W.P. 7405/2025), Justice M. Nagaprasanna of the Karnataka High Court upheld the government's "Sahyog" portal in a 351-page judgment, treating Rule 3(1)(d) of the IT Rules, 2021 as a due-diligence obligation rather than independent censorship power. As The Leaflet's analysis details, the court conceded that Sahyog takedowns are "neither publicly disclosed nor subject to adversarial challenge" — orders flow to platforms, content disappears, and affected users typically learn of removals only after the fact, if at all. X has announced it will appeal to the Supreme Court.
The through-line from Tallinn to Bengaluru is clear. In both systems, the binding judgment about what the public may see is made by an official applying an elastic standard. The difference is that Estonia is at least having the disclosure argument; India's regime is engineered to foreclose it.
DSA-style reporting is the proportionate fix
This is where the EU's Digital Services Act is instructive — not as a model of content rules, but as a model of accountability. Article 24(5) of the DSA requires every online platform to submit a "statement of reasons" for each content-moderation action to a public Commission database, explaining the type of restriction, the grounds, and the facts relied on. The DSA Transparency Database now holds over two billion such statements from 312 active platforms, queryable in near real time.
That is the design principle India should adopt and Estonia should formalize: power to restrict can coexist with a duty to log. A transparency obligation does not stop a government from removing genuine operational intelligence or unlawful content. It simply records that a removal happened, who ordered it, and on what stated ground — converting an invisible, unfalsifiable discretion into something a court, a parliament, or a journalist can later test. Crucially, the DSA shows this can be done without exposing personal data or compromising security: statements are pseudonymized, and redress details are withheld.
The pro-innovation case for this is straightforward. Platforms operating across jurisdictions can already produce statement-of-reasons data; India's IT Rules transparency reports just omit government-ordered removals entirely. Requiring disclosure of the count and stated grounds of state takedown demands — not the sensitive content itself — imposes negligible cost while restoring the feedback loop that keeps a restriction proportionate.
Estonia's lawmakers still have time to pair their new wartime powers with a logging-and-review duty before the law is tested. India's courts and Parliament have less excuse: the X Corp appeal gives the Supreme Court a chance to read a transparency obligation into a regime that has none. The Media Association's warning — that broad wording without disclosure becomes power without limit — is not a uniquely Estonian fear. It is the precise condition India's takedown system has already normalized.