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 It also held that Article 19 protections are available only to citizens, and that Shreya Singhal rested on the repealed 2011 Rules.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.
- Publish a quarterly ledger. Each agency should report notices, URLs, legal ground and compliance outcome. The Sahyog dashboard, which the government itself described in court as tracking requests, takedowns and pending items, already holds this data.
- Make I4C the record-keeper. A national portal whose operator disclaims records is an accountability gap by design. Keeping central logs of notices should be a condition of the portal's operation.
- Notify affected users and enable appeal. Section 69A-style reasoned orders without notice leave speakers with no remedy.
- Separate scams from speech. Fraud and CSAM notices can run on a fast track. Notices touching speech and political content should face stricter review and public reporting.
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.