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Introduction

The Indian government has introduced initiatives to enhance data sharing between law enforcement and stakeholders to combat cybercrime. Union Home Minister Amit Shah has launched the Central Suspect Registry, Cyber Fraud Mitigation Center, Samanvay Platform and Cyber Commandos programme on the Indian Cyber Crime Coordination Centre (I4C) Foundation Day celebration took place on the 10th September 2024 at Vigyan Bhawan, New Delhi. The ‘Central Suspect Registry’ will serve as a central-level database with consolidated data on cybercrime suspects nationwide. The Indian Cyber Crime Coordinating Center will share a list of all repeat offenders on their servers. Shri Shah added that the Suspect Registry at the central level and connecting the states with it will help in the prevention of cybercrime.

Key Highlights of Central Suspect Registry

The Indian Cyber Crime Coordination Centre (I4C) has established the suspect registry in collaboration with banks and financial intermediaries to enhance fraud risk management in the financial ecosystem. The registry will serve as a central-level database with consolidated data on cybercrime suspects. Using data from the National Cybercrime Reporting Portal (NCRP), the registry makes it possible to identify cybercriminals as potential threats.

Central Suspect Registry Need of the Hour

The Union Home Minister of India, Shri Shah, has emphasized the need for a national Cyber Suspect Registry to combat cybercrime. He argued that having separate registries for each state would not be effective, as cybercriminals have no boundaries. He emphasized the importance of connecting states to this platform, stating it would significantly help prevent future cyber crimes.

CyberPeace Outlook

There has been an alarming uptick in cybercrimes in the country highlighting the need for proactive approaches to counter the emerging threats. The recently launched initiatives under the umbrella of the Indian Cyber Crime Coordination Centre will serve as significant steps taken by the centre to improve coordination between law enforcement agencies, strengthen user awareness, and offer technical capabilities to target cyber criminals and overall aim to combat the growing rate of cybercrime in the country.

References:

1. https://pib.gov.in/PressReleaseIframePage.aspx?PRID=2053438

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Introduction

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“an intermediary, on whose computer resource the information is stored, hosted or published, upon receiving actual knowledge in the form of an order by a court of competent jurisdiction or on being notified by the Appropriate Government or its agency under clause (b) of sub-section (3) of section 79 of the Act, shall not ‍, which is prohibited under any law for the time being in force in relation to the interest of the sovereignty and integrity of India; security of the State; friendly relations with foreign States; public order; decency or morality; in relation to contempt of court; defamation; incitement to an offence relating to the above, or any information which is prohibited under any law for the time being in force”

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Law grows by confronting its absences, it heals itself through its own gaps. The most recent notification from MeitY, G.S.R. 775(E) dated October 22, 2025, is an illustration of that self-correction. On November 15, 2025, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2025, will come into effect. They accomplish two crucial things: they restrict who can use "actual knowledge” to initiate takedown and require senior-level scrutiny of those directives. By doing this, they maintain genuine security requirements while guiding India’s content governance system towards more transparent due process. 

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When Regulation Learns Restraint

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To better understand the jurisprudence of revision, one must need to understand that Regulation, in its truest form, must know when to pause. The 2025 amendment marks that rare moment when the government chooses precision over power, when regulation learns restraint. The amendment revises Rule 3(1)(d) of the 2021 Rules. Social media sites, hosting companies, and other digital intermediaries are still required to take action within 36 hours of receiving “actual knowledge” that a piece of content is illegal (e.g. poses a threat to public order, sovereignty, decency, or morality). However, “actual knowledge” now only occurs in the following situations: 

(i) a court order from a court of competent jurisdiction, or

(ii) a reasoned written intimation from a duly authorised government officer not below Joint Secretary rank (or equivalent)

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The authorised authority in matters involving the police “must not be below the rank of Deputy Inspector General of Police (DIG)”. This creates a well defined, senior-accountable channel in place of a diffuse trigger. 

There are two more new structural guardrails. The Rules first establish a monthly assessment of all takedown notifications by a Secretary-level officer of the relevant government to test necessity, proportionality, and compliance with India’s safe harbour provision under Section 79(3) of the IT Act. Second, in order for platforms to act precisely rather than in an expansive manner, takedown requests must be accompanied by legal justification, a description of the illegal act, and precise URLs or identifiers. The cumulative result of these guardrails is that each removal has a proportionality check and a paper trail. 

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Due Process as the Law’s Conscience 

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Indian jurisprudence has been debating what constitutes “actual knowledge” for over a decade. The Supreme Court in Shreya Singhal (2015) connected an intermediary’s removal obligation to notifications from official channels or court orders rather than vague notice. But over time, that line became hazy due to enforcement practices and some court rulings, raising concerns about over-removal and safe-harbour loss under Section 79(3). Even while more recent decisions questioned the “reasonable efforts” of intermediaries, the 2025 amendment institutionally pays homage to Shreya Singhal’s ethos by refocusing “actual knowledge” on formal reviewable communications from senior state actors or judges. 

The amendment also introduces an internal constitutionalism to executive orders by mandating monthly audits at the Secretary level. The state is required to re-justify its own orders on a rolling basis, evaluating them against proportionality and necessity, which are criteria that Indian courts are increasingly requesting for speech restrictions. Clearer triggers, better logs, and less vague “please remove” communications that previously left compliance teams in legal limbo are the results for intermediaries.

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The Court’s Echo in the Amendment

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The essence of this amendment is echoed in Karnataka High Court’s Ruling on Sahyog Portal, a government portal used to coordinate takedown orders under Section 79(3)(b), was constitutional. The HC rejected X’s (formerly Twitter’s) appeal contesting the legitimacy of the portal in September. The business had claimed that by giving nodal officers the authority to issue takedown orders without court review, the portal permitted arbitrary content removals. The court disagreed, holding that the officers’ acts were in accordance with Section 79 (3)(b) and that they were “not dropping from the air but emanating from statutes.” The amendment turns compliance into conscience by conforming to the Sahyog Portal verdict, reiterating that due process is the moral grammar of governance rather than just a formality. 

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Conclusion: The Necessary Restlessness of Law 

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Law cannot afford stillness; it survives through self doubt and reinvention. The 2025 amendment, too, is not a destination, it’s a pause before the next question, a reminder that justice breathes through revision. As befits a constitutional democracy, India’s path to content governance has been combative and iterative. The next rule making cycle has been sharpened by the stays split judgments, and strikes down that have resulted from strategic litigation centred on the IT Rules, safe harbour, government fact-checking, and blocking orders. Lessons learnt are reflected in the 2025 amendment: review triumphs over opacity; specificity triumphs over vagueness; and due process triumphs over discretion. A digital republic balances freedom and force in this way. 

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Sources

• https://pressnews.in/law-and-justice/government-notifies-amendments-to-it-rules-2025-strengthening-intermediary-obligations/ 
• https://www.meity.gov.in/static/uploads/2025/10/90dedea70a3fdfe6d58efb55b95b4109.pdf 
• https://www.pib.gov.in/PressReleasePage.aspx?PRID=2181719 
• https://www.scobserver.in/journal/x-relies-on-shreya-singhal-in-arbitrary-content-blocking-case-in-karnataka-hc/ 
• https://www.medianama.com/2025/10/223-content-takedown-rules-online-platforms-36-hr-deadline-officer-rank/#:~:text=It%20specifies%20that%20government%20officers,Deputy%20Inspector%20General%20of%20Police%E2%80%9D.

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Introduction

India’s telecommunications infrastructure is one of the world’s largest and most complex, serving over a billion users across urban and rural landscapes. With rampant digitisation and mobile penetration, the vulnerability of telecom networks to cyber threats has grown exponentially. On April 24, 2025, the Ministry of Communications (MOC) released a draft of the “Telecommunications (Telecom Cyber Security) Amendment Rules, 2025,” to update the prior Telecommunications (Telecom Cyber Security) Rules, 2024, to improve cybersecurity in India's telecom industry and fortify network security. Public comments and recommendations regarding these draft rules can be sent to the department by July 24, 2025, after they have been made available for public comment. These rules are enacted under the Telecommunications Act, 2023, to enhance national cybersecurity in the telecom domain. These rules aim to prevent misuse of telecom networks and reinforce data and infrastructure protection mechanisms across service providers. 

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Safeguarding the Spectrum: Unpacking the 2025 Cybersecurity Revisions

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The menace of fraudulent SIM cards deals the issue of cyber threats a fresh hand. The rising number of digital scams can also be attributed to unverified or fake mobile numbers. Fraudulent SIM cards have often been linked to various cybercrimes such as phishing, vishing, SIM swapping and identity theft. The situation has worsened in the face of easy availability of pre-activated SIM cards and weak KYC enforcement. In a recent example, as per reports of June 28, 2025, the Special Task Force (STF) found that the accused was operating a criminal nexus where he utilised fake documents and the Aadhaar credentials of law-abiding locals to activate numerous SIM cards. Following activation, the SIMs were either transferred to other telecom carriers for additional exploitation or sold illegally. This poses a serious concern for the data protection of vulnerable individuals, especially those in rural areas, whose credentials have been compromised. 

Given the adverse state of cybersecurity in the telecom industry, the Telecommunications (Telecom Cyber Security) Rules, 2024, were passed on 22nd November, 2024, which put various telecom entities under an obligation to actively prevent cybersecurity threats by adopting such policies that mitigate cybersecurity risks and notify the same to the Central Government. The 2024 Telecom Cybersecurity Rules were a significant step in fortifying India’s telecom infrastructure against cyber threats, but they primarily focused on licensed telecom service providers, leaving behind a large segment of digital platforms operating outside the traditional telecom framework largely unregulated. 

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Expanding the Net: Key Revisions Under the 2025 Cybersecurity Amendment Rules

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The amended rules of 2025 adequately address the regulatory blind spot that is created by the rapid expansion of online services, fintech apps, OTT platforms and social media networks, as these platforms often rely on telecom identifiers such as mobile numbers for user onboarding and service delivery. This regulatory blind spot was exploited for fraud, impersonation and other cybercrimes, especially in the absence of standardised identity verification mechanisms. The proposed regulations would give the government the authority to require private companies’ clients to provide identification if they use a mobile number. For a fee, businesses can also undertake this kind of verification on their own. “ The draft rules introduce a new category called “Telecommunication Identifier User Entities’ (TIUEs), extending cybersecurity compliance obligations to a broad category that now captures any entity using telecom identifiers to deliver digital services. It also creates a unified, government-backed verification framework, enabling better interoperability and uniform user identification norms across sectors. 

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While strengthening national digital security is the goal of the Telecom Cybersecurity (Amendment) Rules, 2025, the proposed rules create a great deal of uncertainty and compliance difficulties, especially for private digital platforms. A broad definition of Telecommunication Identifier User businesses (TIUEs) may include a variety of businesses, including e-commerce services, fintech apps and OTT platforms, under the purview of required mobile number verification. Given that many platforms already have advanced internal processes in place to verify users, this scope uncertainty creates significant concerns regarding operational clarity. 

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Conclusion

The Telecommunications (Telecom Cyber Security) Amendment Rules, 2025, represent a necessary evolution in India’s quest to secure its telecom ecosystem amid growing cyber threats. The draft regulations recognise the evolving landscape of digital services by broadening the legal scope to encompass Telecommunication Identifier User Entities (TIUEs). Though the goal of creating a strong, transparent and accountable framework is admirable, more clarification and stakeholder involvement are required due to the scope’s vagueness and the possible compliance burden on digital platforms. A truly durable telecom cybersecurity regime will require striking the correct balance between security, viability and privacy. 

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References 

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• https://www.cyberpeace.org/resources/blogs/the-government-enforces-key-sections-of-the-telecommunication-act-2023
• https://www.cyberpeace.org/resources/blogs/govt-notifies-the-telecommunications-telecom-cyber-security-rules-2024 
• https://the420.in/uttarakhand-stf-busts-fake-sim-racket-linked-to-cyber-crimes-and-nepal-network/ 
• https://www.thehindu.com/business/dot-puts-out-draft-rules-to-enable-mobile-user-validation/article69741367.ece ‍
• https://www.scconline.com/blog/post/2025/06/28/dot-telecom-cyber-security-draft-policy-update/