I not sure how it's can be against ToS because unlike other case Telegram is actually large enough to actually pay for tens of thousands end point IPs easily even on monthly basis.
And Kremlin minions certainly not going to stop ban subnets now even if will be 1:1000 ratio of Telegram's one and other services.
No, but I don't think that's how it would be spun -- I would exect it to be framed as a ToS violation.