Plugging the Leak - Alternative Solutions to Internet Shutdowns for Exam Leaks
Executive Summary
This paper analyses the issue of using internet shutdowns as a tool to curb instances of cheating, paper leaks and public order disruptions linked to competitive exams in India. This measure has been frequently used in the recent past, and has been criticised due to the collective punishment it imposes on the public. The paper argues that internet shutdowns infringe on the digital rights of citizens, hamper businesses and curtail access to essential goods and services. In this sense, it is a high-cost tool and necessitates a very high bar for its deployment.
Despite their widespread use, internet shutdowns don’t solve the issue of paper leaks, cheating, and misinformation during exams. If the bar to shut the internet is high, there needs to be an effective alternative in place. Paper leaks lead to loss of public trust, career derailment and law and order issues that affect millions of individuals and their families. It’s also an expensive exercise that must maintain its fairness and trustworthiness. So, there is a pressing need for a viable alternative to address the problem of exam disruption.
This paper suggests a combination of community policing and high-stakes events management strategies as a viable option to internet shutdowns. This alternative considers the issues of digital rights, economic costs, law and order and public trust to recommend a targeted response to the problem of exam disruption.
1.Introduction
India has had over 800 cases of state-issued internet shutdowns as of 2025. In principle, this instrument is used by the state to protect public order or in the interest of national security. Yet, one of the top use cases of internet shutdowns is to prevent cheating, paper leaks and rumour-mongering or misinformation during high-stakes competitive exams. As per a report published by Human Rights Watch and Internet Freedom Foundation, as many as 29% of internet shutdowns in 2022 happened to prevent cheating during exams.
Competitive exams in India receive a very high volume of applications and are often the entry barriers to highly sought-after jobs and education. In the past few years, several high-stakes exams such as National Eligibility cum Entrance Test - Undergraduate (NEET-UG), and Bihar Public Service Commission (BPSC) have been cancelled, leading to widespread protests and public outrage.
Internet shutdowns have become a widely used and heavily criticised tool to prevent paper leaks, which have become frequent occurrences. As this tool is inherently broad-based and leads to extensive collateral damage, the proportionality and effectiveness of internet shutdowns have been questioned. It also raises the issue of the digital rights of individuals and the presence of accountable and well-functioning systems to ensure that internet shutdowns are deployed after careful consideration of business, legal and societal implications.
In this paper the authors examine the costs associated with internet shutdowns to argue for a more targeted intervention to tackle the problem of paper leaks. Section 2 looks into the cost of internet shutdowns; section 3 examines the economy of exams in India; and in section 4, the authors present the existing legal and policy frameworks around this issue. Section 5 looks at the evidence presented in earlier sections to ascertain the proportionality and effectiveness of internet shutdowns.
In sections 6 and 7, the paper presents recommendations and a combination of strategies that can act as an Option Short of Shutdowns (OSOS). Here, an execution plan with short- and long-term actions to address the issue are also offered. This approach considers the incentives of the stakeholders and projects outcomes with regards to protection of digital rights, redressal of the law and order issue and preservation of public trust in the exam system.
In conclusion, the paper recommends a targeted and proportionate approach to the issue that respects the digital and economic rights of its citizens and calls for greater accountability from and greater collaboration between authorities.
2. The Cost of Internet Shutdowns
As Digital India grows, the internet is no longer just a medium of social connectivity. It is the site of work, education and information sharing, things that are crucial to the functioning of society. This means that any blanket deployment of internet shutdowns imposes a collective punishment on the general public in the affected area by restricting their access to essential services such as banking and education, and the ability to conduct businesses online. It also affects access to government welfare programmes like Mahatma Gandhi National Rural Employment Guarantee Act (MNREGA), and food distribution through the Public Distribution System (PDS) system. As per the No Internet Means No Work, No Pay, No Food report published by the Human Rights Watch and Internet Freedom Foundation in June 2023, internet shutdowns have led to loss of wage earnings and hurt sectors such as healthcare, education, the gig economy, etc, as well as the freedom of expression in varying degrees, depending on the scale and duration of the shutdown.
The report also argues that since internet shutdowns affect mobile internet connectivity more than Wi-Fi, the impact of this tool is disproportionately experienced by the rural and economically weaker sections of society who rely on mobile internet. As per the January 2025 data published by the Telecom Regulatory Authority in India (TRAI), mobile subscribers form the majority of internet user base in India, and as of November 2024, over 95% of India’s 944.76 million internet users in India were using the internet on their phones.
Figure 2: Number of Internet Subscriptions in India (in Millions)
Visualisation based on data from Telecom Regulatory Authority of India, 2025
Although there is no official data available in India regarding the economic costs of internet shutdowns, independent organisations like Top10VPN have estimated the cost of internet shutdowns in India at $322.9 million (₹ 2805.71 crore as of February 18, 2025) in 2024 alone. This, according to their estimate, is attributed to 2,920 hours of shutdown affecting 67.7 million people. India also leads the world in the number of instances of internet shutdowns and holds the record for highest instances of internet shutdowns for over 6 years in a row.
Figure 3: Cases of Internet Shutdowns in India vs Other Countries
Visualisation based on data from Rest of World 2024
As per the Top10VPN report, India ranks number 6 in terms of the economic cost of shutdown, trailing countries such as Bangladesh, Myanmar and Sudan that experience high levels of civil unrest. This shows that despite the government’s push for greater digitalisation and the existing legal and policy guidelines to exercise caution and proportionality for internet shutdowns, this tool has been liberally used in India, causing significant loss to the government, businesses and society.
3. The Cost of Exams
In India, competitive exams are high-stakes events that gatekeep access to some of the most sought-after jobs and education. These exams also receive high volumes of applications each year, which means that there is an entire exam-preparedness network and economy in place. This network includes coaching centres, exam influencers, parents, teachers and several clusters of the coaching industry across the country. As per a 2024 Economic & Political Weekly article, the market revenue of the coaching industry in India stood at INR 58,000 crore and is projected to reach INR 1.3 lakh crore by 2028. The industry has been criticised for its misleading and aggressive marketing strategies, resulting in added anxiety, false expectations and mental health issues amongst aspirants. This led to calls for regulations and issuance of guidelines for coaching centres by the Central Consumer Protection Authority in November 2024. Coaching centres have also emerged as a key component of the leaked-paper supply chain in several investigations, including NEET UG 2024.
Exams are also an expensive exercise for the testing agencies. Taking exam fees as a proxy for expenditure (although official data on the use of exam fees is not available), five of the highest-stakes exams in India collected over 360 crores in exam fees in 2023 (see Table 1 below).
Table 1: Exam fees for the top five national-level exams in 2023
For ease of calculations, the authors assume the lowest exam fees applicable for reserved categories. UPSC is an exception as female candidates and candidates from SC/ST/PwBD categories are exempt from paying the exam fee. Fees have been sourced from the official websites for the exams.
NEET-UG, IIT JEE, GATE, CAT, UPSC Civil Exam
At the social level, the issue of paper leaks and the social outrage around it points to the underlying problem of unemployment and quality education in India. As per the National Crime Records Bureau (NCRB) data published in 2022, student suicides because of exam failure and anxiety constitute 7.6% of all suicide cases in India. The high volume of aspirants for every job and college seat makes exams highly competitive and stressful. This scenario creates additional pressure for students and parents; motivates the demand for leaked papers; and is the reason for outrage in case of exam cancellations. Each exam cycle puts enormous financial and psychological stress on aspirants and their families, and this investment depends on the fairness and trustworthiness of the exam process.
Thus, the temptation to take a swift, strong and sweeping action, such as an internet shutdown, to deal with the issue is understandable. However, going back to the three questions posed in the previous section, there needs to be clear evidence that this is an appropriate, effective, and sustainable response to the problem. The next two sections of this paper present the existing policy and legal frameworks on the subject and argue that the cost of shutdowns outweigh the need for it.
4. Existing Policies and Legal Measures
The Telecommunications Act, 2023, allows the government to impose internet shutdowns in case of public emergency or in the interest of public safety. In 2024, the Temporary Suspension of Telecommunication Services Rules, 2024 was promulgated under the Telecommunications Act, 2023, which primarily governs the suspension of telecom services in India. As per this rule, temporary shutdown of telecom services in a region on grounds of public emergency can last up to 15 days at once and allows for review of these shutdowns within five days of the suspension.
In Anuradha Bhasin v Union of India, the Supreme Court held that indefinite internet shutdowns by the State are not permissible under the Indian constitution. It also said that any order on internet shutdowns will come under judicial scrutiny and will need to be published. The Supreme Court also went on to ascertain that “the freedom to practice any profession or carry on any trade, business or occupation over the medium of internet enjoys constitutional protection under Article 19”, and that internet shutdowns are in violation of these fundamental rights.
While the Court has repeatedly stated the need for a test of proportionality before any restrictions are imposed, a 2021 Lok Sabha Standing Committee on Communications and Information Technology report clearly indicates that’s not been the case. As per the report, since there are no definitions as to what constitute a public emergency or ‘public safety in either the Act or the Rule, internet shutdowns have been ordered based on subjective assessment, and often for routine policing and administrative purposes, such as to prevent cheating in exams and local crime. More importantly, internet shutdown orders have not been published despite the Supreme Court ruling, resulting in a lack of data and evidence to justify shutdowns. As per the Human Rights Watch and Internet Freedom Foundation 2023 report, 11 of the 28 states that shut down internet did so without publication of official orders. Additionally, many states were found to have disregarded due process or review boards or record findings.
In 2024, India passed the Public Examinations (Prevention of Unfair Means) Act that calls for strict punishments and institutional accountability in cases of paper leaks. The impact of this Act is yet to be understood. In June 2024, the Ministry of Education established a high-level committee of experts that was tasked with reviewing the functioning of the National Testing Agency (NTA). In its report submitted to the Ministry, the committee proposed a series of measures aimed at preventing exam-paper leaks and enhancing data security. Some of the key recommendations included the deployment of end-to-end encrypted digital question-paper delivery systems, real-time tracking of question-paper sets through blockchain-based authentication, stricter vetting and background checks for personnel involved in exam logistics and the establishment of a dedicated cybersecurity unit within the NTA. The report also emphasised decentralising paper-setting processes and reducing human intervention through automation to minimise risks of manipulation or unauthorised access. Once again, the deployment of these measures is yet to be seen.
It is clear that the existing legal frameworks uphold proportionality and set a high bar for internet shutdowns, but in reality, shutdowns remain a popular means of signalling action to society for an issue that elicits outrage—but without solving the underlying problem.
5. Is Internet Shutdown the Right Solution?
So far, we have established that paper leaks are a serious problem that upset both the students and the administration. Between 2019 and 2024, India has had over 41 documented cases of exam leaks across 15 states, affecting 1.4 crore job seekers.
Figure 4: State-wise Instances of Paper Leaks in India, 2019 –24
Source: Visualisation based on Indian Express data, 2024
On the other hand, internet shutdowns are a high-cost tool that impose collective punishment on the public. Thus, there needs to be a strong justification for its deployment.
There are three key questions here:
1. Are internet shutdowns effective in stopping paper leaks and exam disruptions?
There is no clear evidence or official data to suggest that internet shutdowns are effective in preventing paper leaks. Paper leaks are the result of corruption, organised crime, weak security measures and cyber vulnerability, and hence any solution to the problem will need to address all these factors. Internet shutdowns alone cannot solve systemic corruption and organised criminal actions. Motivated buyers and sellers in an expensive and high-stakes trade of leaked papers can switch to tools like Virtual Private Networks (VPNs) and The Onion Router (TOR) to bypass internet shutdowns. All other digital users -from businesses to the general public, however, become collateral damage .
2. Are internet shutdowns a proportional and appropriate response to exam-paper leaks?
Internet shutdowns are a crude response to exam-paper leaks. They impose collective punishment and infringe on the digital rights of citizens. States have failed to meet the standards of necessity, proportionality and due process in their shutdown orders, and shutdowns are often used pre-emptively and without adequate justification. A more proportionate and targeted response would be to strengthen the physical security apparatus of exam centres, or use multi-stage examinations or two-factor-verification to solve specific issues of impersonation or tampering. This would also be in accordance with the Public Examinations Prevention of Unfair Means Act, which calls for proper definitions of offenses.
3. Does it address the core issue of paper leaks and is it a sustainable solution?
Internet shutdowns attempt to tackle the supply side of paper leaks and control information flow around exam time. They don’t solve for the demand side. Measures such as public awareness around penalties, reporting of suspicious activities and exam stress management have not been used as standard practices to combat the problem of paper leaks. Internet shutdowns also don’t solve the coordination, negotiation, financial transactions, or corruption that leads to the incidence of paper leaks.
In the next two sections, the authors propose an Option Short of Shutdowns to address the issue of paper leaks. This option calls for targeted interventions using existing state resources and building best practices to create a robust exam system over time.
6. Option Short of Shutdowns (OSOS) for Exams
This paper argues for a three-fold approach to the issue of internet shutdowns during competitive exams. This approach upholds civil liberties and digital rights as enshrined in the Anuradha Bhasin v Union of India judgement, recommends community involvement and leverages existing state capacity to target specific aspects of exam related crimes in India.
The approach is as follows:
Community Outreach: As discussed earlier, exam aspirants in India exist within a large network of coaching centres, schools and social media influencers. This network influences and informs the students, and is sometimes involved in the crime nexus of paper leaks. Thus, establishing bridges within this network can be useful for law-enforcement agencies. A community outreach initiatives could include activities such as awareness programmes run for students along with creating trusted channels for information sharing and secure avenues for reporting suspicious activities.
High-Stakes Event Management: Depending on the volume of applications and the education/job at stake, exams in India are an exercise of event management. This includes managing exam centre infrastructure, security arrangements, verification systems and the chain of custody for the question paper. It also includes a wide range of technology use, as some exams may be held using computers while others use pen and paper or OMR sheets. Securing each technology may require different levels of cost, expertise and strategy.
High-stakes events such as the Republic Day parade or the Kumbh Mela are run using clear protocols around event management; a similar approach should be adopted to conduct exams. This measure will include targeted surveillance and intelligence gathering and have clearly defined protocols for each step of the exam process. Clear reporting and accountability measures will need to be placed to ensure proportionate and justifiable deployment of surveillance tools and timely intelligence sharing among stakeholders.
This approach will require gradual implementation, as institutional capacity to deploy this approach will slowly need to be built.
Consultation and Advisory on Best Practices: This is a long-term strategy that involves continuous data collection and analysis to identify emerging threats and recurring patterns. A structured mechanism will need to be established for sharing intelligence across states and agencies. This will ensure that standardised protocols are developed based on on-ground data and system realities. Here, the paper recommends periodical publication of best practices and advisories to different testing agencies. The feasibility of using emerging technologies, such as blockchain, should also be explored.
7. Execution Plan for the OSOS
In this section, the authors present an execution plan for the OSOS that allows for slow and gradual implementation, factoring in current capacity as well cost of implementation.
Figure 5: Visual Representation of the Three-fold OSOS Execution Plan
Source : Created by the authors of this paper
Community Outreach: This measure is executed by local law-enforcement agencies as well as the State Police. Together, they will be responsible for implementing a strategy of soft deterrence and counselling.
This will involve mapping of educational institutions, coaching centres, education influencers as well as locations such as printing shops that are part of a district’s exam ecosystem. Law-enforcement officers will then build a network across coaching centres, school administrators, counsellors, parents and social influencers in their district by actively engaging with them.
The police units will then run awareness campaigns for candidates, parents and staff at schools and coaching institutes within their jurisdiction. These awareness programmes will focus on creating awareness around the penalties of cheating, misinformation, the need for integrity of the exam process, and on stress management.
It will also aim to create a direct and secure channel for reporting any coercion or suspicious activities. Additionally, if a paper leak does occur, this channel can also be used by the police to circulate any information about leaks via rapid response teams to assuage the other stakeholders’ grievances. In this sense, rather than shutting down the internet, authorities will be able to leverage it to maintain public order.
Since maintaining law and order is a core function of the police, preventing paper leaks is in the police’s direct interest. Additionally, it will get support from parents, educational institutes and candidates. Educational institutions will gain credibility by supporting well-conducted exams. Candidates and their networks will get a direct channel of communication on a policy that impacts them the most. Lastly, families will be reassured that their exam-giving members will not be unfairly targeted.
The community outreach strategy can be deployed immediately, as it does not require augmenting existing police capacity. It is a low-cost approach that can act as a deterrent while also building trust amongst the stakeholders.
High-Stakes Event Management: Conducting an exam of national importance engages a wide variety of stakeholders. The high-stakes event management approach attempts to create a dialogue between all the concerned actors. This is done by co-ordinating all the participants’ responses towards the collective goal of conducting a leak-free exam.
For this step, the actors are the union and state law-enforcement agencies (with special emphasis on cybercrime/cybersecurity divisions), intelligence agencies, exam-conducting bodies such as the UPSC, State PSCs, NTA, CBSE etc, telecom service providers, internet service providers and cybersecurity firms and experts. All these actors will be part of a panel established to streamline their responses before an exam of national importance.
In this panel, the exam-conducting bodies will share their tentative annual calendars in consultation with law-enforcement agencies. This approach engages the latter from the planning stage itself and gives them the opportunity to plan in advance and ensure preparedness.
Additionally, law-enforcement agencies and intelligence agencies will monitor open-source channels such as social media as well as encrypted channels such as the dark web. Union and state agencies will also have to create a mechanism to share their findings with each other from these domains. Specifically, cyber monitoring will involve monitoring communication on leaked questions papers, habitual offenders, financial transactions related to paper leaks. Despite these measures, if a paper leak does happen, then this intelligence apparatus will direct an internet shutdown localised to the area where the leak occurred. This will compartmentalise the damage and prevent a broad-based internet shutdown.
Telecom and internet service providers have an incentive to participate in this approach because better surveillance will reduce the need for shutdowns and mitigate the economic loss service providers have to bear. Private cybersecurity firms and technology experts will also play a central role in this strategy. They can fill the gap in state capacity by improving the intelligence-gathering capabilities of union and state law-enforcement agencies.
As this approach requires building capacity by creating mechanisms for dialogue, information sharing and localised internet shutdowns, it is a long-term project. Unlike the community outreach approach, it will require investment through additional funding and a gradual roll-out over one to two years.
Law-enforcement authorities will need to gather information and data from past incidents of paper leaks to understand crime patterns and profile suspects. Intelligence will also need to be gathered from online sources such as social media and the dark web for suspicious communications and financial transactions.
Further, locations important to the exam ecosystem such as printing shops will be regularly monitored for suspicious activities. An SOP will be developed for targeted surveillance and events monitoring and shared across states and deployed based on the importance of the exam. Law-enforcement authorities can refine their surveillance based on information gathered through the community outreach approach described earlier. It is important to note that these surveillance tactics will be solely used for the purpose of prevention of exam leaks and will focus on individuals under suspicion. Aside from this, law-enforcement agencies will also be mobilised as per the exam calendar to volatile exam locations to prevent public unrest. This is a proportional approach where state capacity will be deployed according to the scale of the exam.
Consultation and Advisory on Best Practices:
If all exam leaks are reported and declared publicly, it can build government accountability, improve transparency and raise the level of trust exams enjoy in India. In service of this goal, the Ministry of Education and Ministry of Home Affairs should jointly create a set of policy guidelines. These guidelines should mention best practices across states and also explore technology-based solutions for securely distributing question papers (here the recommendations of the High-Level Committee of Experts’ report to the Ministry of Education can be referred to). Their recommendations to use end-to-end encryption and blockchain technologies to secure as well as track exam papers can be deployed using current technological advancements. The guidelines should also make it compulsory to report all exam leaks and related security breaches to the intelligence sharing mechanism mentioned in the high-stakes event management approach.
Since these guidelines require information sharing from all over the country, state governments’ ministries of education and home affairs will be key participants, along with exam-conducting bodies. Additionally, creating a platform such as a high-powered committee, an All-India council or national policy group to share and discuss best practices from across states will require investment in state capacity. This could translate into needs such greater funds, more administrative personnel and/or external expertise.
Creating guidelines, acquiring and analysing instances of leaks and bringing together multiple private and public bodies are long-term solutions. These will also be subject to bureaucratic delays and resistance before they can take effect. Thus, this component will take three–four years to execute.
While this three-pronged strategy offers a solution to exam leaks, there are unintended consequences to executing it. First, educational institutes might be hesitant to cooperate with local law-enforcement agencies due to fears of increased scrutiny or legal action. Second, there could be jurisdictional conflicts between law-enforcement agencies. These turf wars could create gaps in monitoring and reporting, creating fertile grounds for exam leaks. Lastly, unverified reports can lead to false accusations and unnecessary harassment of innocent candidates, teachers and institutions. To mitigate these risks, law-enforcement agencies will have to establish clear accountability frameworks and transparency in all policy decisions.
8. Conclusion
The persistent issue of exam-paper leaks has significantly disrupted the lives of millions of job seekers and eroded public trust in the system. Heavy-handed measures to curb these leaks, such as internet shutdowns, fail to address their root causes, come at a high economic cost and are unconstitutional.
Therefore, the challenge of preventing exam leaks without resorting to internet shutdowns demands a strategic, multi-stakeholder response. The proposed three-fold approach—community outreach, high-stakes event management, and consultation on best practices—offers a sustainable, targeted alternative that prioritises both security and civil liberties.
This approach considers issues of adaptation, state capacity and uptake, and recommends pathways for collaborative action. Blanket shutdowns hinder essential services, disproportionately impact marginalised communities and fail to address the core issue of exam-paper leaks. Instead, a proactive, intelligence-led approach offers a solution that safeguards digital rights and upholds constitutional principles while ensuring the integrity of India’s competitive exam system.
Disclaimer: Author views are personal and do not reflect the stand of organisation.
Authors
Ragini Thakur serves as a Manager of Research & Impact at National Skill Development Corporation
Samyak S is a student of Public Policy at Takshashila’s Postgraduate Programme.
Devina Sikdar is a Forensic Scientist and Criminal Justice Researcher and a fellow of the Law Enforcement & Policing Fellowship 2024–25