Sanchar Saathi App Pre-Installation: Even Best Case Scenario “Not Proportional”: IFF

On November 21, 2025, the DoT issued a mandate to install a security app on all Indian phones.

The internet freedom foundation has come out against the direction, calling it disproportionate and against fundamental right to privacy.

Speaking to the media on December 2, 2025, Communications Minister Jyotiraditya Scindia clarified that the Sanchar Saathi app is fully optional, deletable anytime, and activated only by user choice.

 The Internet Freedom Foundation has come down heavily on the Department of Telecommunications (DoT), for its direction to pre-install the Sanchar Saathi mobile app on all cellular devices manufactured or imported to India.

 “The direction by requiring manufacturers and importers of mobile handsets to pre-install the Sanchar Saathi App represents a sharp and deeply worrying expansion of executive control over personal digital devices,” said IFF in a statement issued on X on December 2, 2025.

 On Monday, December 1, 2025, reports circulated that on November 21, 2024, the DoT, through its AI & Digital Intelligence Unit (AI & DIU) had, under the Telecommunications (Telecom Cyber Security) Rules, 2024, had issued a direction on pre-installing the Sanchar Saathi app.

 While the full text of the direction was not been made public by the DoT, the tech news website Medianama released the full text on Monday. Based on that the IFF has said that it will follow up with the DoT via an RTI which asks not just for the directive’s text but also the reasoning behind it. The IFF has said it will shortly release “analysis as well as steps, if required to support a challenge to it in a court of law.”

 The DoT has said, before, that the Sanchar Saathi app is meant to enhance telecom security of Indian citizens by allowing users to report fraud, block lost or stolen phones, verify the mobile connections registered in their name, and “stay informed about the latest updates on telecom security.”

 The IFF, however, points out that though enhancing security is, on face value, is a legitimate state claim, “the means chosen are disproportionate, legally fragile, and structurally hostile to user privacy and autonomy.”

IFF points out that in the directive mandates that the pre-installed app be “readily visible” and that, its functionalities are not disabled or restricted.

 “In plain terms, this converts every smartphone sold in India into a vessel for state mandated software that the user cannot meaningfully refuse, control, or remove,” says IFF, while pointing out that to carry out the objective would require system-level access similar to OEM system apps, which users cannot then disable.

 “That design choice erodes the protections that normally prevent one app from peering into the data of others, and turns Sanchar Saathi into a permanent, non-consensual point of access sitting inside the operating system of every Indian smartphone user,” says IFF.

 Speaking to the media on December 2, 2025, Communications Minister Jyotiraditya Scindia clarified that the Sanchar Saathi app is fully optional, deletable anytime, and activated only by user choice.

 In 2017, the Supreme Court had in the case of K.S. Puttaswamy reaffirmed the Indian citizens’ fundamental right to privacy, and set out a proportionality test for any erosion of the right, including that it has to be proportionate and necessary.

 “Even if we assume legality and necessity for the limited purpose of checking the genuineness of devices, the order clearly stumbles on proportionality,” says IFF, pointing out that the government has the Sanchar Saathi web portal, SMS-based KYM (Know Your Mobile) services, and USSD codes, all of which would allow a user to perform the tasks of verifying IMEI numbers and detect fake handsets “without a permanent app baked into the firmware.”

 There is no technical explanation in the order for why a one-time or occasional verification exercise justifies a resident, non-removable application with elevated privileges that lives on the phone for the lifetime of the device. Forcing a permanent app installation for a sporadic verification function is not a marginal overreach; it is a textbook example of disproportionate state action under the Puttaswamy standard.

 The DoT order invokes “telecom cyber security” but fails to define the app’s functional perimeter. Calling the directive’s language “so vague that it invites function creep as a design feature, not a bug,” the IFF has pointed out the app could easily be turned against citizens as well.

 “Today, the app may be framed as a benign IMEI checker. Tomorrow, through a server side update, it could be repurposed for client side scanning for ‘banned’ applications, flag VPN usage, correlate SIM activity, or trawl SMS logs in the name of fraud detection… In effect, the state is asking every smartphone user in India to accept an open ended, updatable surveillance capability on their primary personal device, and to do so without the basic guardrails that a constitutional democracy should insist on as a matter of course.”

 Calling the directive “deeply concerning” the IFF has said it filed RTI with the Department of Telecom not only for a copy of this direction/order but also the underlying justification on how and why it was issued.