The judgment in Telegram FZ LLC v. Union of India exposes a structural gap in the necessity stage of proportionality doctrine under Anuradha Bhasin v. Union of India. [1] This paper argues that the Delhi High Court collapsed two analytically distinct propositions: (1) that narrower measures were tried and failed, and (2) that no narrower measures were structurally available to the government. The court treated these as equivalent without accounting for the jurisdictional reality that Telegram, as an undomiciled foreign platform, could not structurally comply with targeted takedown orders. This distinction is decisive. [2] Foreign platforms without domestic presence in India have no corporate entity to serve, no assets to attach, and no representative to mandate compliance through. The necessity stage of proportionality doctrine cannot simply ignore this reality by asserting that the government exhausted all available tools. It must instead examine whether the regulatory architecture itself precludes certain measures. This paper proposes a statutory independent review body operating pre-enforcement to examine this distinction explicitly, supplemented by a graduated response ladder and bilateral treaty mechanisms with the jurisdictions where foreign platforms are domiciled. Without these reforms, Section 69A becomes a blunt instrument whenever foreign platforms are involved, and proportionality doctrine becomes a post-hoc ratification of executive action rather than a principled constraint upon it. [1] Telegram FZ LLC v. Union of India, 2026 SCC OnLine Del 4750 (Delhi H.C. June 19, 2026), W.P. (C) No. 8259 of 2026. [2] Anuradha Bhasin v. Union of India , (2020) 3 SCC 637.