A Coalition's Preemptive Warning
On August 5, 2026, Access Now and the #KeepItOn coalition — more than 370 organizations across 106 countries — publicly urged Zambian President Hakainde Hichilema to keep networks on through the country's August 13 general election. The appeal cited a specific pattern: election-related disruptions in 2016 and 2021, a two-day 2020 shutdown the government attributed to rainfall (an explanation opposition officials disputed), and a August 2021 social-media block — covering WhatsApp, Facebook, Twitter, and Instagram — that a Zambian court later ruled unconstitutional. The coalition also flagged Zambia's 2025 Cybercrimes Act and Cybersecurity Act as laws with "the potential to further restrict freedom of expression," while crediting Hichilema for declining to sign a Public Gathering Bill criticized as vague and overbroad.
India's Larger, Longer-Running Pattern
Zambia's four shutdowns in a decade are a rounding error next to India's record. Access Now's 2025 #KeepItOn report counted 313 shutdowns across 52 countries globally — the highest annual figure ever documented — and found India alone responsible for 65 of them, ranking second worldwide behind only Myanmar, even though 65 was India's lowest count since 2017. India's Software Freedom Law Centre tracker shows the pattern continuing into 2026, with shutdowns already recorded this year in Rajasthan, Bihar, Jammu and Kashmir, Haryana, Uttarakhand, and Delhi — the last tied to a July 20 protest march during the Monsoon Session of Parliament.
The Reform That Wasn't Quite One
India did rewrite its shutdown rulebook. The Telecommunications (Temporary Suspension of Services) Rules, 2024, issued under Section 20 of the Telecommunications Act, 2023, replaced the 2017 rules that governed shutdowns for most of the past decade. Under the new framework, Home Secretaries at the central or state level authorize suspensions; orders must now state reasons, a defined geographic area, and a duration; and Review Committees — composed of the Cabinet Secretary, Law Secretary and Telecom Secretary at the Centre, or their state equivalents — are empowered to set aside orders, a power the 2017 committees lacked.
That is a real improvement on paper. But as the Software Freedom Law Centre's analysis of the rules notes, post-2024 orders from Jammu and Kashmir now cite the correct rule and specify location and service tier, yet "the justifications remain identical to earlier years: vague references to 'anti-national elements,' 'social media misuse.'" The Review Committees still have no judicial member, no public reporting requirement, and no citizen standing to challenge a suspension before a neutral body. PRS India's tracking of the rules separately flags that district-wide shutdowns for public examinations have continued to exceed what the framework's own emergency-and-safety language contemplates.
The Case Regulators Would Make
It is worth stating the government's strongest argument fairly. Examination fraud is not a hypothetical harm: Rajasthan's REET and RPSC exams have been repeatedly compromised by coordinated cheating rings using messaging apps, and India's 2026 NEET medical-entrance exam was cancelled outright after leaked questions overlapped with the live paper by more than 100 items. A district-level mobile blackout during a three-hour exam window is a narrower, more targeted intervention than many alternatives, and unlike a protest-related shutdown, it has a fixed, self-terminating rationale. Genuine public-safety shutdowns during communal violence occupy similarly defensible terrain — the state has a real interest in preventing coordinated violence, and the 2023 Act's requirement that orders name a duration and geography is a meaningful floor relative to the pre-2017 era, when shutdowns could be ordered with almost no paper trail at all.
Why Paperwork Isn't Proportionality
The problem is that India's own Supreme Court set a higher bar than paperwork six years ago. In Anuradha Bhasin v. Union of India (January 10, 2020), the Court held that indefinite or blanket shutdowns are impermissible, that restriction orders cannot be shielded from public view, and that any suspension must satisfy a four-part proportionality test: a legitimate aim, a rational connection to that aim, no less-restrictive alternative that would work as well, and a duration and scope actually tailored to the emergency. A 2024 rule requiring an order to state a geography and duration satisfies the letter of that test without satisfying its substance — a broad district shut down for a three-hour exam, or a citywide mobile blackout during a march that authorities could have policed with less blunt tools, can recite the required fields and still fail Bhasin's least-restrictive-means standard.
The Standard Already Exists
Zambia's #KeepItOn appeal and India's own courts are converging on the same principle: shutdowns are a proportionality failure, not a security tool, when a narrower option exists and goes untried. India does not need a new law to close this gap — it needs the Review Committees its 2024 rules already created to actually publish findings and include an independent or judicial member, exactly as the Bhasin bench anticipated. Until then, the country that ranks second globally for shutdown frequency will keep producing better-documented versions of the same blunt instrument.