Research and Articles

• In its judgement dated 19 June 2026, Justice Tejas Karia of the Delhi High Court ("Court") upheld directions issued by the Ministry of Electronics and Information Technology ("MeitY") on 16 June 2026 and 17 June 2026¹ (“Judgment”), directing the blocking of Telegram and its associated URLs across India until 22 June 2026 and the suspension of Telegram's message-editing functionality until 30 June 2026.

• The Court noted allegations that Telegram had been repeatedly used to facilitate fraud associated with the NEET UG 2026 examination, including the dissemination of misleading information. Against this backdrop, the Court held that MeitY's decision to temporarily restrict access to Telegram was a proportionate measure aimed at preserving the integrity of the examination and fell within the ambit of its statutory powers under Section 69A of the IT Act.

• The Judgment significantly expands the reach of Section 69A of the Information Technology Act, 2000 ("IT Act"). The Court held that Section 69A of the IT Act authorizes MeitY not only to block specific content but also to direct the blocking of public access to an entire software platform. It further characterized a platform-wide blocking order as the "least restrictive" available measure in the circumstances. By endorsing this interpretation, the Judgment broadens the scope of governmental blocking powers under the IT Act and may expose online platforms to blocking orders that could materially affect their operations and accessibility in India.

FACTUAL BACKGROUND

On 3 May 2026, the National Eligibility-cum-Entrance Test (Undergraduate) ("NEET UG 2026"), India's nationwide entrance examination for admission to undergraduate medical and dental courses, was conducted. Shortly thereafter, allegations surfaced that the examination paper had been leaked². In response, the National Testing Agency ("NTA"), the autonomous body responsible for conducting national-level entrance examinations, announced on 12 May 2026 that the examination stood cancelled and that a re-examination would be conducted on 21 June 2026³.

Against this backdrop, the NTA informed the MeitY on 21 May 2026 of the alleged misuse of Telegram by third parties in connection with NEET UG 2026. MeitY subsequently convened a meeting with representatives of the NTA and Telegram to assess the scale and nature of the alleged misuse.

Thereafter, on 9 June 2026, MeitY shared with Telegram a list of Telegram channels, accounts, and bots that had allegedly been used to facilitate fraud relating to NEET UG 2026. Telegram disabled access to the identified content.

Notwithstanding these measures, MeitY issued directions on 16 June 2026 ("Impugned Order") under Section 69A of the IT Act, directing that:

1. Telegram and its associated URLs be blocked across India till 30 June 2026;

2. Telegram to disable its message-editing functionality till 30 June 2026;

3. the Department of Telecommunication to instruct internet service providers and application stores to block/disable access to Telegram till 22 June 2026; and

4. the matter be placed before the Committee (“Committee”) constituted under Rule 7 of the Information Technology (Procedure and Safeguards for Blocking for Access of Information by Public) Rules, 2009 ("2009 Rules") within forty-eight hours for review and recommendation.

Aggrieved by the Impugned Order, Telegram filed a writ petition before the Delhi High Court under Articles 226 and 227 of the Constitution seeking the quashing of the Impugned Order.

Thereafter, pursuant to Rule 7 of the 2009 Rules, the Committee considered reports submitted by the NTA, the Indian Cyber Crime Coordination Centre ("I4C"), and Telegram. In its subsequent order ("Final Order"), the Committee concluded that:

1. Telegram was being misused in connection with fraud relating to NEET UG 2026 and confirmed the Impugned Order;

2. despite Telegram's takedown efforts and engagement with authorities, unlawful channels and bots continued to proliferate through backup channels, rendering narrower interventions ineffective; and

3. the measures directed under the Impugned Order were necessary and proportionate to safeguard the integrity of the examination process and maintain public order.

ISSUES, ARGUMENTS, COURT’S OBSERVATIONS AND ANALYSIS

ISSUE NO. 1: WHETHER THE IMPUGNED ORDER FALLS WITHIN THE SCOPE OF THE BLOCKING POWER CONFERRED BY SECTION 69A OF THE IT ACT

Arguments of the Parties

Court's Observations

Section 69A of the IT Act empowers the Central Government to direct the blocking of public access to any information generated, transmitted, received, stored, or hosted in any computer resource, where it is necessary to do so in the interest of sovereignty and integrity of India, defence of India, security of the State, public order, or for preventing incitement to the commission of any cognisable offence.

The Court accepted the Respondent's interpretation of Section 69A. It observed that "information", as defined in Section 2(1)(v) of the IT Act, includes, among other things, data, messages, text, images, sounds, voices, codes, computer programmes, software, and databases. The Court further noted that the term "computer resource" under Section 2(1)(k) includes a computer, computer system, computer network, data, computer database, and software. Having regard to the breadth of these definitions, the Court held that a platform such as Telegram falls within the scope of these provisions, being a code, computer programme or software. Accordingly, the Court concluded that Section 69A empowers the Government to direct the blocking of Telegram and that the Impugned Order was within the scope of the statutory power conferred by the IT Act and the 2009 Rules.

The Court further noted that Telegram's compliance with directions to disable specific content under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 ("2021 Rules") was not determinative of the validity of the directions issued under Section 69A. In its view, the removal of individual items of content had been undertaken pursuant to the 2021 Rules, whereas the blocking order was imposed on account of the platform's architectural features, which, in the Court's assessment, necessitated blocking the platform itself in order to prevent its misuse.

ANALYSIS 

1. Contextual Interpretation of Section 69A of the IT Act Does Not Support Blocking an Entire Intermediary

   The Court's reasoning proceeds from the broad definitions of "information" and "computer resource" contained in Sections 2(1)(v) and 2(1)(k) and concludes that a platform such as Telegram falls within the ambit of these provisions. This interpretation, however, raises questions regarding the intended scope of Section 69A.

   Section 2 of the IT Act begins with the qualifier "unless the context otherwise requires", indicating that statutory definitions must be construed in light of the provision in which they are employed rather than applied mechanically. Section 69A empowers the Government to block access to "any information generated, transmitted, received, stored or hosted in any computer resource". Read contextually, the language of Section 69A appears to distinguish between three separate concepts: the information sought to be restricted, the computer resource through which such information is made available, and the intermediary directed to implement the restriction. Information is the object of regulation; the computer resource is the medium through which such information exists; and the intermediary is the entity capable of implementing the blocking direction. By treating the intermediary platform itself as the subject matter of the blocking power, the Judgment arguably collapses these distinct concepts and extends Section 69A beyond its textual structure.

2. Broader Scheme of the IT Act Distinguishes Between Information and Intermediaries

   The broader scheme of the IT Act reinforces the above interpretation. Section 67C of the IT Act imposes obligations on intermediaries to preserve and retain information hosted on their services. The provision itself recognises a distinction between an intermediary and the information hosted, transmitted, or stored through it. The intermediary is conceived as the custodian, repository, or facilitator of information; it is not itself characterised as information.

   Similarly, Section 79 of the IT Act grants safe harbour to intermediaries in respect of "third party information, data, or communication links". Section 79(2)(a) expressly contemplates intermediaries as entities providing access to communication systems through which information generated by third parties is transmitted, stored, or hosted. Were an intermediary itself to be characterised as "information" merely because it operates through software, the conceptual distinction on which both the preservation obligation under Section 67C and the safe-harbour framework under Section 79 rest would be difficult to sustain.

   The difficulty is also linguistic. Users do not transmit or receive Telegram itself; rather, they transmit and receive information through Telegram. Treating the entire application as "information" capable of being blocked under Section 69A therefore stretches the statutory language beyond its ordinary and contextual meaning.

3. Judicial Precedent Indicates a Narrow Scope for Section 69A

   The Judgment also appears difficult to reconcile with the Supreme Court's treatment of Section 69A. In Shreya Singhal v. Union of India (“Shreya Singal”)⁴, the Supreme Court characterised Section 69A as a narrowly drawn provision containing several procedural safeguards and contemplated directions requiring intermediaries to restrict access to specific information. Similarly, in Anuradha Bhasin v. Union of India (“Anuradha Bhasin”)⁵, the Supreme Court reiterated the limited nature of the blocking power and observed that while Section 69A permits the blocking of particular content or websites, it cannot be employed to impose a wholesale restriction on internet access.

   These decisions suggest that Section 69A was intended to enable targeted restrictions directed at identified information, not the disabling of an intermediary platform in its entirety. This understanding is further reinforced by Section 69A(3) of the IT Act, which contemplates penalties, including imprisonment for a term which may extend to seven years and a fine, for intermediaries that fail to comply with blocking directions issued under the provision. The structure of the provision thus treats intermediaries as the recipients of blocking directions, not as the subject matter of the blocking power itself.

4. The Judgment Expands Intermediary Obligations Beyond the Existing Statutory Framework

   The Court's interpretation also carries significant implications for the intermediary-liability framework. Both the Impugned Order and the Final Order proceed on the premise that, notwithstanding Telegram's engagement with governmental authorities and repeated takedown measures, unlawful channels and content continued to emerge on the platform. The continued availability of such content appears to have been treated as a basis for imposing restrictions on the platform itself. The Court reinforced this by holding that compliance with content-level takedowns under the 2021 Rules was not determinative, since the block was directed at Telegram's architecture rather than at any particular item of content.

   That approach sits uneasily with Section 79 and the 2021 Rules. Under the statutory framework, intermediaries are required to exercise due diligence and make "reasonable efforts" to prevent the hosting, display, upload, publication, transmission, storage, updating, or sharing of prohibited content. In Shreya Singhal, the Court clarified that an intermediary's obligation to remove or disable content arises only on "actual knowledge", in the form of a court order or a notification from the appropriate Government or its authorised agency. The reasoning underlying the Impugned Order, by contrast, appears to assume that Telegram was obliged not merely to remove identified content but to ensure that similar content did not subsequently reappear. That recasts the intermediary's duty from one of reasonable diligence into something approaching strict responsibility for user conduct.

   While neither the Impugned Order nor the Judgment expressly holds that intermediaries are strictly liable for user-generated content. But the practical effect of the reasoning, particularly once content-level compliance under the 2021 Rules is treated as irrelevant to a block premised on architecture, is that an intermediary may face platform-wide restrictions despite complying with takedown directions and engaging with regulators, simply because unlawful actors continue to create new channels, accounts, or content. Such an outcome risks expanding intermediary obligations beyond those contemplated by Section 79, the 2021 Rules, and the principles articulated in Shreya Singhal.

ISSUE NO. 2: WHETHER THE IMPUGNED ORDER SATISFIES THE TESTS OF NECESSITY, PROPORTIONALITY AND LEAST RESTRICTIVE MEANS LAID DOWN IN ANURADHA BHASIN 

Arguments of the Parties

Court's Observations

The Court observed that the Impugned Order satisfied the tests of proportionality and least restrictive means. It noted that Telegram, unlike conventional platforms, possesses certain architectural features, including the ability to store large volumes of data, an extensive bot ecosystem, and a username-based system that does not require users to interact through phone numbers. According to the Court, these features facilitate the creation and dissemination of fraudulent content. The Court further observed that even where an offending channel was identified and disabled, it was relatively easy for the operators to create mirror channels and continue the impugned activities.

On this basis, the Court held that the requirements of proportionality laid down in Anuradha Bhasin were met, concluding that: (i) the blocking order pursued the legitimate objective of preserving the integrity of NEET UG 2026 and maintaining public order; (ii) there existed a rational nexus between the restriction and that objective; (iii) the urgency of the impending re-examination, coupled with Telegram's architecture, rendered the restriction necessary; and (iv) the temporary nature of the order demonstrated that it was the least restrictive measure available. 

ANALYSIS:

1. Necessity and the Least Restrictive Means Requirement

   The Court's conclusion on the existence of a legitimate objective is difficult to dispute. Protecting the integrity of a nationwide public examination attended by over twenty lakh candidates undoubtedly constitutes a legitimate governmental interest. The more difficult question, however, concerns the latter stages of the proportionality inquiry, namely, whether the platform-wide restriction was in fact necessary and whether it represented the least restrictive means of achieving that objective.

   Proportionality requires a comparative inquiry. In Anuradha Bhasin, the Supreme Court explained that proportionality is concerned with the relationship between means and ends and referred to Lord Diplock's aphorism that one must not "use a steam hammer to crack a nut, if a nutcracker would do." The principle requires the State to demonstrate that the restriction adopted does not exceed what is necessary to achieve the legitimate objective, an inherently comparative exercise that measures the chosen restriction against the alternatives reasonably available.

   Viewed against this framework, the Judgment does not appear to undertake a detailed comparative assessment. It identifies the legitimate governmental objective of preserving the integrity of the NEET UG 2026 examination and preventing threats to public order. It also places considerable emphasis on the temporary duration of the blocking order and Telegram's technical architecture. However, these considerations principally address the legitimacy of the objective and, to some extent, the suitability of the measure. The Judgment does not appear to undertake the distinct inquiry required at the necessity stage, namely, whether the same objective could have been achieved through alternative measures that interfered less with Telegram's operations and the rights of its lawful users. Judgment appears to focus primarily on the temporary duration of the blocking order and the technical characteristics of Telegram's platform. While both considerations are relevant, they do not by themselves establish necessity. A restriction may be narrowly tailored in time while remaining broad in scope.

   This distinction is significant because, as Anuradha Bhasin recognised, the degree of restriction, its territorial scope, and its duration must all bear a reasonable relationship to what is actually necessary to address the identified harm. The Court there specifically cautioned that if the State's plea that targeted regulation is technologically difficult were accepted without scrutiny, the Government would effectively receive a "free pass" to impose complete blockades whenever narrower measures presented operational challenges. The State is instead required to consider the "various options" that burden fundamental rights most minimally.

   That reasoning assumes particular importance in the present case. The Judgment records the Respondents’ contention that prior takedown measures had proved ineffective and that operators of offending channels were able to create mirror channels, backup channels, reserve channels, bots, rotated handles and successor accounts. However, the Judgment does not appear to independently assess why other less restrictive alternatives, short of a platform-wide restriction, would have been insufficient before resorting to the blocking of Telegram as a whole.

   The failure of one targeted measure does not, without more, establish that all narrower measures were ineffective. A basic entity-by-entity takedown regime may fail because it is reactive, but that does not answer whether more targeted but escalated measures could have addressed the specific vectors of harm identified by the Respondents. In particular, the Judgment does not appear to engage meaningfully with the following alternatives.

   • Identification through phone-number linkage and platform metadata: Telegram accounts are linked to mobile numbers.⁶ While bots do not require separate phone numbers, they are created and controlled through Telegram user accounts, which may themselves be linked to phone numbers. Telegram may also possess safety-related metadata such as IP addresses, device details, app/session information and username-change history.⁷ Law-enforcement agencies could have used this information as investigative leads by matching phone numbers with telecom subscriber records, tracing IP addresses through internet service providers, identifying repeated login or device patterns, and correlating these details with payment trails such as UPI IDs, QR codes, bank accounts or wallets used to collect money from candidates. Therefore, even if operators used foreign numbers, VPNs, burner accounts or rotated handles, the relevant question was whether reasonable investigative routes existed to trace or cluster repeat offenders before resorting to a platform-wide block. The Judgment does not appear to undertake this inquiry, despite recording that offending actors were using backup channels, bots, rotated handles and burner accounts to evade takedown measures.

   • Disclosure-based remedies recognised by the Delhi High Court: In Neetu Singh v. Telegram FZ LLC⁸ and Raj Shamani v. John Doe⁹, the Delhi High Court directed Telegram to disclose information relating to channel operators and account holders to facilitate action against individuals operating fraudulent channels. The Judgment does not explain why similar disclosure-based measures could not have been pursued in the present case before imposing a blanket restriction on the intermediary platform. This omission is significant because the Respondents’ own case was that identifiable operators or operator-clusters were repeatedly reappearing through mirror channels and successor accounts.

   • Operator-focused enforcement measures: The Respondents could also have explored preservation requests and disclosure of subscriber information, account details, IP logs, device identifiers, login histories, username-change histories, linked sessions, invite-link creation logs, bot-controller information and other metadata capable of assisting investigative agencies in identifying the individuals operating the offending channels. Section 67C allows the government to mandate that intermediaries “preserve and retain” computer records. Such measures may be complex and resource-intensive, but difficulty of enforcement does not, without more, establish that platform-wide blocking was the least restrictive measure available.

   • Account-level and admin-level bans: Telegram could have been directed not merely to remove offending channels, but to disable or restrict the accounts/admins controlling them, including linked bot accounts and successor channels created by the same admin cluster. Telegram’s platform already recognises account-level restrictions: its Privacy Policy states that accounts may be limited from contacting strangers or banned in more serious cases, and its API documentation also recognises user restrictions affecting the ability to create channels or chats.¹⁰ A direction aimed at freezing the ability of identified admins, bot controllers or linked operator clusters to create or administer new public channels during the examination window would have been materially narrower than disabling access to Telegram for all users.

   • De-indexing from Telegram search instead of full blocking: Telegram could have been directed to temporarily restrict public search and discoverability for NEET-related public channels and bots, instead of blocking the entire platform. This would have made offending channels harder to find through search, recommendations, or public usernames, while still allowing ordinary users to use Telegram for private messaging and lawful purposes.

   • Invite-link and forwarding restrictions for flagged networks: Telegram could have been required to disable invite links, forwarding, cross-posting and audience migration from identified scam channels and their successor networks.

   • Payment-trail intervention: Since the alleged fraud involved payment collection, QR codes/barcodes and bank accounts, the State could have frozen suspicious bank accounts, UPI IDs, QR codes and payment gateways, and issued directions to banks/payment intermediaries. Such measures would have targeted the economic incentive behind the alleged fraud without disabling lawful communication by all Telegram users.

   The concern, accordingly, is not that the State was constitutionally bound to persist with channel-by-channel takedowns after they had shown limited efficacy. It is that the Judgment appears to equate the failure of ordinary channel-level takedowns with the failure of all narrower alternatives. That equation is not compelled. A measure may be ineffective in its basic form yet effective when strengthened through disclosure obligations, account-level bans, dynamic mirror-channel takedowns, invite-link revocation, forwarding restrictions, de-indexing, public-channel creation freezes, bot-controller restrictions, preservation obligations, and payment-chain enforcement.

   A related difficulty concerns suitability. The Respondents themselves acknowledged that the blocking measure could be circumvented through VPNs. That admission tells against both the suitability and the necessity of a platform-wide block. The operators of fraudulent channels, sophisticated enough to run bot networks, rotated handles, and successor accounts are precisely the users most likely to evade the block through a VPN, while the millions of ordinary users who do not use such tools bear the full burden of the restriction. A measure that the State concedes can be evaded by the very actors it targets sits uneasily with the requirement of a genuine rational nexus between the restriction and its objective and weakens the case that a blanket block was necessary as opposed to merely convenient.

2. Disproportionate Impact on Intermediaries and Lawful Users

   The Court's reasoning places considerable weight on the importance of NEET UG 2026 and on the potential effect of misinformation on "public order." These concerns are significant, but neither the Impugned Order nor the Judgment substantially engages with the impact of a platform-wide block on Telegram's lawful users. Such a restriction affects not only those allegedly engaged in unlawful conduct but also the millions who use the platform for legitimate purposes.

   More fundamentally, the rationale adopted is not unique to NEET UG 2026. India conducts numerous major competitive examinations each year, i.e., JEE, the UPSC Civil Services Examination, the Chartered Accountancy examinations, CUET, GATE, CLAT, CAT, and the various State Public Service Commission examinations, each involving lakhs of candidates and carrying significant public importance. If the significance of a competitive examination, coupled with the persistence of unlawful content on a platform, is sufficient to justify blocking an intermediary, the same reasoning could be invoked across a wide range of examinations and other matters of public importance. The logical consequence is that platforms such as Telegram could be blocked for substantial parts of the year, normalising platform-wide blocking as a recurring regulatory response, an outcome with a disproportionate impact both on the intermediary's right to carry on business and on the rights of the many users who rely on the platform for lawful purposes.

COMPARATIVE PERSPECTIVES: INTERNATIONAL JURISPRUDENCE ON PLATFORM BLOCKING

The difficulties identified above find a close parallel in comparative jurisprudence, which has generally proceeded from a distinction between unlawful content and the platforms through which that content is disseminated. This distinction is reflected in the jurisprudence of the European Court of Human Rights. In Cengiz and Others v. Turkey (2015), the Court considered a Turkish order blocking access to YouTube because a small number of videos allegedly violated domestic law.¹¹ Recognising that YouTube was not merely a repository of content but an important medium through which users received and imparted information, the Court accepted that even users who were not the direct targets of the order could claim to be affected by it. It held that although domestic law authorised action against specific unlawful content, it did not justify blocking an entire platform. Of particular significance was the Court's observation that the block rendered inaccessible large quantities of lawful material unrelated to the offending videos, imposing substantial collateral burdens on users with no connection to it.

Further, General Comment No. 34 of the United Nations Human Rights Committee recognises that Article 19 of the ICCPR protects not only expression itself but also internet-based systems of information dissemination.¹² While restrictions may be imposed in limited circumstances, the Committee states that they should generally be content-specific, and that generic bans on websites or information systems are incompatible with the requirements of necessity and proportionality under Article 19.

The European Court adopted a similar approach in Ahmet Yıldırım v. Turkey (2012), which arose when Turkish authorities, seeking to block a single website hosted on Google Sites, ultimately blocked access to the entire Google Sites domain.¹³ The Court held that the measure interfered with the applicant's freedom of expression even though his own website was wholly unrelated to the allegedly unlawful content, characterising the issue as the "collateral effect" of a blocking measure directed at specific content but implemented so as to render lawful material inaccessible.

The Court developed this reasoning in Vladimir Kharitonov v. Russia (2020), where the applicant's website was blocked not for its own content but because it shared an IP address with a blacklisted site.¹⁴  Treating the measure as an incidental consequence of an order directed at different content, the Court held that it interfered with both the applicant's right to impart information and the public's right to receive it—the lawful site having become inaccessible merely through an "incidental connection, at the infrastructure level" with unlawful content hosted elsewhere.

The principle emerging from these decisions is directly relevant to Section 69A. Each rest on a distinction between unlawful information and the infrastructure through which it is communicated, cautioning against treating a platform as the object of regulation merely because unlawful content passes through it.

CONCLUSION

The Judgment is likely to have significant implications for intermediaries operating in India, as it appears to expand the scope of Section 69A of the IT Act beyond its conventional understanding. By upholding the blocking of an intermediary platform on the basis of its architectural features and the alleged misuse of the platform by certain users, the Court has adopted an interpretation that differs from the content-specific approach reflected in the 2021 Rules and in Shreya Singhal. The Judgment may also have the effect of broadening the obligations of intermediaries, as platforms could potentially face platform-wide blocking measures in circumstances involving unlawful content hosted or transmitted through their services.

The implications of the judgment may extend beyond the facts of the present case, particularly in situations involving public examinations, elections, or other matters of significant public interest. To the extent this interpretation is relied upon in future cases, it may influence the manner in which Section 69A is invoked and applied and could contribute to a broader understanding of the Government's blocking powers under the IT Act.

Shivani Choudhary and Pradyumn Sharma
You can direct your queries or comments to the authors.

¹ Telegram FZ LLC and Anr. v. Union of India and Ors., Delhi High Court, W.P. (C) 8259 of 2026

² See here: https://www.aljazeera.com/news/2026/5/26/come-back-my-son-indian-exam-leak-leaves-trail-of-death-despair-anger

³ See here: https://web.archive.org/web/20260512213730/https://www.thehindu.com/education/neet-ug-2026-cancelled-what-happens-next-heres-what-students-need-to-know/article70969954.ece

⁴ Shreya Singhal v. Union of India, Supreme Court, W.P. (Crl) 167 of 2012

⁵ Anuradha Bhasin v. Union of India, Supreme Court, W.P. (C) 1031 of 2019

⁶ See Telegram, Privacy Policy, clause 3.4 ("Phone Number and Contacts"), https://telegram.org/privacy.

⁷ See Telegram, Privacy Policy, clause 5.3 ("Spam and Abuse"), https://telegram.org/privacy.

⁸ Neetu Singh v. Telegram FZ LLC, Delhi High Court, CS (COMM) 282/2020

⁹ Raj Shamani v. John Doe, Delhi High Court, CS COMM 1233/2025

¹⁰ Please see https://core.telegram.org/method/channels.createChannel

¹¹ Cengiz and Others v. Turkey, App. Nos. 48226/10 and 14027/11, ECtHR (Second Section), Judgment of 1 December 2015, paras. 49-56, 61-65.

¹² UN Human Rights Committee, General Comment No. 34 (Article 19: Freedoms of Opinion and Expression), UN Doc. CCPR/C/GC/34 (12 September 2011), para. 43.

¹³ Ahmet Yıldırım v. Turkey, App. No. 3111/10, ECtHR (Second Section), Judgment of 18 December 2012, paras. 66-68.

¹⁴ Vladimir Kharitonov v. Russia, App. No. 10795/14, ECtHR (Third Section), Judgment of 23 June 2020, para. 40-46.