India runs two routes for removing online content: a 2009 blocking power with a committee and written reasons, and a faster safe-harbour notice route rebuilt in 2021. A Congress government built the first, a BJP government the second, and the courts have upheld both so far. Australia's eSafety system shows the same drift toward informal requests, but it publishes the count.
India's Ministry of Electronics and Information Technology told Parliament it directed the blocking of 1,385 web addresses in 2017 under section 69A of the Information Technology Act, and 7,502 in the first ten months of 2023. X was the largest single target in 2023, with 3,390. Officials later told The Indian Express the total reached about 24,300 in 2025; Parliament has not been given that figure. The ministry's own counts drift: 6,096 addresses for 2021 in a March 2022 answer, 6,118 in December 2023. The blocking rules require "strict confidentiality" about every request and action.
The front door. Section 69A came from the IT (Amendment) Act 2008, in force from 27 October 2009, when Manmohan Singh of the Congress party was prime minister. It allows blocking on six grounds, including sovereignty, security and public order, by written order of a designated officer of at least Joint Secretary rank after a committee process. A platform that refuses faces up to seven years' jail. In 2015 the Supreme Court, in Shreya Singhal, struck down the speech offence in section 66A, upheld 69A and its rules, and read down the separate safe-harbour clause, section 79(3)(b): a platform loses protection only after a court order or a government notice tied to the grounds in Article 19(2) of the Constitution.
The side door. Rules notified on 25 February 2021, under Narendra Modi's BJP government, rebuilt that second route. Since October 2024 the Home Ministry's cybercrime centre has run the Sahyog portal with the IT and telecoms departments; by March 2025, 28 states, 5 union territories and 6 central ministries had named officers who can send notices. A platform that ignores one risks losing its legal shield. An RTI reply reported by The Indian Express counted 2,312 orders through the portal from October 2024 to October 2025, 1,392 of them to WhatsApp. Each order can list many links.
The courts. X Corp argued that only section 69A can block. On 24 September 2025 the Karnataka High Court dismissed its petition, calling Sahyog "an instrument of public good" and holding that Article 19 protects citizens, not a foreign company. The same court had dismissed X's challenge to 69A orders in June 2023 with costs of 50 lakh rupees. X appealed. On 22 July 2026 the Supreme Court stayed the appeal and related petitions while it decides whether to hear them itself. Meanwhile the ministry amended the rule on 22 October 2025: notices must be reasoned, issued by an officer of Joint Secretary rank or above, and reviewed monthly by a Secretary. In February 2026 it cut the removal deadline from 36 hours to 3.
Test the claim. The government told the court Sahyog is "a mere facilitation portal" and that binding blocking power stays with 69A. Formally, that holds: a notice is not a 69A order. In effect, it falls short. Refusal costs the shield, the clock is now three hours, review sits inside the same government, and no official count is published.
Australia, like for like. The Online Safety Act 2021, a government bill passed on 23 June 2021 with seven Opposition amendments, lets the eSafety Commissioner order class 1 material removed within 24 hours. In 2024-25 the Commissioner gave 17 formal removal notices across all schemes and 2,823 informal notices and requests, and received 19,821 complaints about illegal content covering 47,292 web addresses, 85 percent involving child abuse. Australia does better on three counts, all evidenced. The Act forces an itemised annual count. Decisions can go to a tribunal, which in February 2025 held that even an informal alert to X was in effect a reviewable notice; the Commissioner appealed. And when she sought worldwide removal of the Wakeley church stabbing video in 2024, the Federal Court refused to extend the injunction, and she discontinued on 5 June 2024. The shared pattern is also evidenced: both countries lean on a lighter channel beside the formal power, and Australia's runs at 2,823 informal requests to 17 formal notices. A per-head comparison would mislead, because India counts web addresses and orders, and Australia counts notices.
The build. A builder's rule: one door, a published count of everything that goes through it, and an outside reviewer who can reopen it.
Pattern so far: no treaty or foreign template was found behind India's regime, and both main parties built part of it. As with the debt rules, the number officials report is the narrow one; the faster channel sits outside India's official count. Shared outcomes are not shared intent.
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