India content takedowns and intermediary liability

Gujarat's 190,633 Sahyog Takedown URLs Show Why India Needs a Public Ledger, Not Just Senior Sign-Off

An RTI reply shows Gujarat Police flagged one URL every six minutes via Sahyog while the portal's operator keeps no records. Oversight needs published data.

Gujarat Police's Sahyog Takedowns People of Internet Research · India 5,358 Takedown notices sent Gujarat Police notices via Sahyog … 190,633 URLs covered Total URLs across all Gujarat noti… ~36 URLs per notice Average implied by the RTI totals. peopleofinternet.com
Gujarat Police's Sahyog Takedowns People of Internet Research · India 5,358 Takedown notices sent 190,633 URLs covered ~36 URLs per notice peopleofinternet.com

Key Takeaways

An RTI reply dated 28 October 2026 gives the first state-level count of how heavily India's Sahyog Portal is used. Gujarat Police sent 5,358 takedown notices covering 190,633 URLs to intermediaries over roughly two years, MediaNama reported. That is about 36 URLs per notice, or one URL every six minutes. The same reporting says the Centre's Indian Cyber Crime Coordination Centre (I4C), which runs the portal, told a separate RTI that it keeps no records of notices issued through it. Those records, it said, sit with state and union territory police.

The strongest case for Sahyog

The government's argument deserves a fair hearing. Cybercrime moves faster than court dockets. Fraud links, impersonation accounts and child-safety material are harmful within hours. A single-window portal that routes notices to intermediaries, replacing emails and faxes to ad hoc contacts, is plausibly better for everyone. Platforms get a standard format and can flag defective notices. Police get a clear channel. The Karnataka High Court accepted this reasoning. In its 24 September 2025 order in X Corp v. Union of India (Writ Petition 7405 of 2025, Justice M. Nagaprasanna), it dismissed X's challenge. SFLC.in's analysis reports that the court called the portal a lawful mechanism under Section 79(3)(b) of the IT Act and Rule 3(1)(d) of the 2021 IT Rules. It also held that Article 19 protections are available only to citizens, and that Shreya Singhal rested on the repealed 2011 Rules.

What the Gujarat number actually shows

The figure does not prove misuse. Many of those URLs may be scam pages and plainly illegal material. But the number exposes a structural problem: nobody can say. The Gujarat reply, according to MediaNama, gave an aggregate figure with no breakdown by legal ground or intermediary, and no outcomes. It reports that the reply came only after a first-appeal transfer and a second appeal. The central operator holds no ledger. A system that issues 190,633 URL requests from one state, while the national operator cannot count them, cannot be audited by courts, legislators or the people whose speech was removed.

The volume also matters for a legal reason. The Supreme Court in Shreya Singhal v. Union of India (2015) read down Section 79(3)(b) so that an intermediary's "actual knowledge" arises from a court order or a notification by the appropriate government or its agency. In paragraph 117, it also said the order or notification "must strictly conform to the subject matters laid down in Article 19(2)." Whatever the Karnataka High Court's view of the 2011 Rules, that constitutional boundary is the test any takedown regime has to meet. At about 36 URLs per notice, it is hard to believe each URL received individual Article 19(2) scrutiny. Without records, no one can check.

The October 2025 fix is necessary but not sufficient

The government did tighten the process. According to Khaitan & Co's note, MeitY amended Rule 3(1)(d) on 22 October 2025, effective 15 November 2025. Notices must now come from an officer of Joint Secretary rank (or Director where no such officer is appointed), or Deputy Inspector General rank for police. They must state reasons, and all notices face a monthly review. Intermediaries had complained of large volumes of notices lacking legal basis, factual context or specific URLs. Those are real improvements.

But they are internal safeguards. The review is by the same government that issues the notices. The note itself flags that the relationship between Rule 3(1)(d) and the Section 69A blocking process remains unresolved, a point the Karnataka judgment did not reconcile. Nothing in it requires publishing counts, informing the affected user, or giving the speaker a way to contest removal. The Gujarat RTI reply covers a period that mostly predates the amendment, so it cannot tell us whether the new rank threshold changed volumes. Only data published going forward can.

A proportionate remedy

The fix is cheap and does not require abandoning the portal.

India's open internet is not helped by either extreme. Platforms that ignore valid notices fail users who are being defrauded. A state that removes content at industrial scale with no public count invites over-removal, and over-removal chills lawful speech and the startups that carry it. Sunlight is the proportionate response. The Gujarat figure is a data point only because one anonymous requester persisted through two appeals. Accountability should not depend on that.

Sources & Citations

  1. MediaNama: Gujarat Police flagged one URL every six minutes through Sahyog Portal
  2. Karnataka High Court order, X Corp v. Union of India, WP 7405/2025 (24 Sept 2025)
  3. Supreme Court, Shreya Singhal v. Union of India (2015)
  4. SFLC.in analysis of X Corp v Union of India judgment
  5. Khaitan & Co: Amendment to Rule 3(1)(d) of the IT Rules, 2021