11th July, 2025
Since October 2024, the Government of India’s centralised digital interface, dubbed the SAHYOG Portal (“SAHYOG”), has quietly reshaped the contours of content takedown and intermediary liability in the country. Built initially as an emergency coordination tool during the COVID-19 pandemic, SAHYOG now serves as the primary mechanism through which law enforcement agencies and government departments issue removal requests to platforms like Twitter (now X) and Facebook. While the portal promises speed and uniformity, its history of function creep, absence of a clear statutory footing, and opaque processes have ignited a fierce debate over state overreach, due process, and digital rights. In this deep dive, we trace SAHYOG’s evolution from public-health infrastructure to a de facto censorship engine, unpack its shaky legal underpinnings under Sections 69A and 79(3)(b) of the Information Technology Act, 2000, and explore how civil society, courts, and platforms themselves are pushing back.
From Pandemic Tracker to Content Regulation Hub
In mid-2020, as India grappled with successive COVID-19 waves, the Ministry of Home Affairs (MHA) and the Ministry of Electronics & Information Technology (MeitY) collaborated with the newly formed Indian Cyber Crime Coordination Centre (I4C) to build SAHYOG as a health-and-public-safety tracking tool.1 Its initial mandate was narrow: aggregate data on hospital bed availability, oxygen supplies, and pandemic hotspots, and facilitate inter-departmental alerts and resource allocation. That same interface also supported coordination between central ministries, state governments, and law enforcement agencies to combat pandemic-related fraud, hoarding, and misinformation campaigns.
In this form, SAHYOG functioned like a digital emergency operations center, drawing inspiration from crisis-management platforms worldwide. There are several international analogues to India’s SAHYOG that have been used for crisis management, especially during the COVID-19 pandemic. These platforms, such as the NHS Data Store in the United Kingdom or the HHS Protect in the United States, typically facilitated real-time coordination among public health, emergency response, law enforcement, and sometimes the military.
Government spokespeople have touted SAHYOG as part of India’s broader “Digital India” push: a one-stop portal that would cut through red tape and ensure seamless communication among agencies. The idea is that in any crisis, be it a natural disaster, terror attack, or cyber incident, the portal can instantly connect sanctioned nodal officers, share intelligence, and dispatch takedown or blocking orders.2 This model mirrors pandemic responses elsewhere, where governments leveraged dashboards and APIs to coordinate policies, public advisories, and enforcement actions. The MHA’s response before Courts emphasizes, from social media companies to Internet service providers, into a unified operational workflow.
By late 2024, minutes of internal MHA meetings reveal that SAHYOG was “repurposed” for content regulation without any new legislation or parliamentary debate.3 Instead of relying solely on Section 69A’s established blocking process, agencies began issuing takedown notices under Section 79(3)(b), the safe-harbour carve-out, directly through the portal. Section 69A of the IT Act empowers the central government to block online content on specified grounds, like national security or public order, through a formal process involving inter-ministerial oversight, reasoned orders, and (except in emergencies) a pre-decisional hearing, as laid out in the 2009 Blocking Rules. In contrast, Section 79(3)(b) does not grant blocking powers but creates an exception to intermediary immunity if they fail to act upon “actual knowledge” of unlawful content, limited by the Shreya Singhal judgment to court orders or official government notices.
Agencies began using the SAHYOG portal to issue direct takedown notices under 79(3)(b), bypassing the procedural safeguards of 69A without any legislative amendment or debate, effectively transforming SAHYOG from a crisis-response tool into an opaque censorship mechanism run through executive fiat. This shift was never debated in Parliament, nor was it accompanied by amendments to the Information Technology Act or its Rules. In effect, SAHYOG silently absorbed powers that the law assigned to multiple agencies, transforming from a crisis-management hub into a parallel censorship regime.
Lack of Statutory Foundation
Although the government defends SAHYOG by citing Sections 69A and 79(3)(b), neither provision mentions nor authorizes a centralized digital interface. As stated above, Section 69A mandates a written order, reasons in writing, and an opportunity for the intermediary or content creator to be heard before blocking public access. Section 79(3)(b) simply states that intermediaries lose immunity if they “fail to remove” content upon notification by the “appropriate government or its agency.” Neither grants authority to consolidate all takedown functions into a single portal with standardized forms, automated workflows, or bulk-notice capabilities. In the absence of express legislative sanction, SAHYOG remains a bureaucratic innovation, not a law.
Further, under Section 69A, blocking orders must comply with these due-process requirements – i) a written order signed by the competent authority; ii) a detailed statement of reasons explaining why the content falls within the statutory grounds (sovereignty, security, public order, defamation, etc.), and iii) an opportunity to be heard, including the ability to appeal to a review committee. These steps, upheld as essential safeguards in the Supreme Court’s landmark Shreya Singhal v. Union of India judgment (2015), ensure that content is not arbitrarily removed and that affected parties have recourse to challenge orders.
By contrast, SAHYOG’s workflows are entirely digital and automated, with no requirement for explanatory narratives or individualized review. Platforms have reported that they receive takedown requests stamped simply with the issuing “agency code” and a hyperlink to the portal, but no contextual details or legal reasoning.4 There is no built-in appeal button, and the only recourse for intermediaries is to escalate requests back through the portal. This process starkly violates Section 69A’s due process ethos by eliminating written reasons, oral hearings, and meaningful access to remedies. SAHYOG’s democratization of content takedown powers means that lower-rank police officers in district and city stations can issue bulk notices, often without any apparent legal vetting.
Further, because the portal uses numeric agency codes, even platforms cannot easily determine which department or individual issued a notice. This opacity thwarts public interest litigation, obstructs parliamentary scrutiny, and shields officials from legal liability when they issue wrongful or malicious takedown orders.
Moreover, SAHYOG offers no internal appeals mechanism. Courts have pontificated that procedural safeguards are not mere formalities but integral to upholding constitutional rights. Yet, users and platforms alike are left without clarity on how to challenge an erroneous or politically motivated takedown. Civil society experts warn that, without statutory reform or independent oversight, SAHYOG effectively empowers the executive to police speech free from checks and balances.5
X Corp. v. Union of India
In 2024, in a missing child’s case before the Delhi High Court, X contended that it “cannot be compelled” to join SAHYOG, invoking the Supreme Court’s Shreya Singhal precedent to assert that only Section 69A’s blocking process applies to content removal. The court has issued notices to the Centre to clarify SAHYOG’s legislative footing and procedural safeguards, with the Centre responding that SAHYOG was developed to create a “safe cyberspace”.6 Other entities like Meta, however, informed the court that they had completed their onboarding and were consequently discharged from the matter.
In April 2025, X Corp. filed a public interest petition in the Karnataka High Court challenging its forced onboarding onto SAHYOG. The company argued that Section 79(3)(b) did not authorize any “mechanism or portal” to issue takedown notices; it merely states that intermediaries lose safe harbour if they “fail to remove” content upon notification by authorized agencies. It further stated that Section 69A, the only provision granting censorship power to the government, provides explicit procedural safeguards which SAHYOG bypasses. Thus, the portal effectively creates a parallel regime with no statutory basis, violating the doctrine of due process and constitutional free speech guarantees.7 The matter will be finally heard on July 9, 2025.
The cases have crystallized a rare alliance: technology companies, civil-society advocates, and constitutional experts now question the government’s unchecked digital infrastructure expansion.8 The SAHYOG Portal exemplifies the dangers of digital infrastructure repurposing without transparent legal mandates. As X Corp. v. Union of India unfolds in Karnataka, courts will face a pivotal question: can administrative convenience ever override constitutionally enshrined procedural rights?
For policymakers, the SAHYOG saga offers a cautionary tale. Digital governance demands legislative clarity, procedural safeguards, and independent oversight, especially when state agencies wield the power to shape public discourse. Otherwise, India risks entrenching a “censorship portal” that may outlast every crisis it was designed to address, eroding trust in both government and digital platforms.
