A lot of people do forget that often times in comics that nothing is truly immune to anything as writers will distort facts to fit the plot they are trying to tell. Also I logically would not expect Magneto's helmet to be completely immune to any and all telepathic attacks as the telepathy of the Phoenix or a being using the power cosmic or maybe even a telepathic feat by the Living Tribunal should not be stopped by something earth bound as his helmet. If his helmet had cosmic origins and was instilled with a technology well beyond human means then depending on the its origins (maybe it would come from the White Hot Room or something of the sort) I would say it has full immunity to telepathy. But other than that I say that the helmets gives extremely high resistance that hasn't been broken as of the time it was granted the title of immunity because for all practical purposes it was immune. The strongest telepath of the time, Xavier, couldn't get through. That was validation enough (at the time) for it to be considered immune to telepathic attacked. By the way, who ascertained that it was immune? By whose authority was it called immune?
On to the topic of Jean Grey. As I have already stated, upon time of it being titled immune, Xavier couldn't even get in. That would be enough evidence to convince anybody of its immunity and therefore it was considered so. Jean on the other hand had a lot more power than Xavier in the telepathic field (though probably not the same amount of skill). The previous threshold for immunity was ruptured by her because she reached a level of power that was previously impossible to achieve. No longer is the helmet completely immune to all telepathic attacks on earth as the mark for immunity has risen. We can see this concerning Jean a couple of times. First (and though not everybody agrees to this) she had access to magneto's mind during the Dazzler incident, secondly she got through Juggernaut's helmet which was also considered immune to telepathic attack since Xavier couldn't get through, thirdly she got past Emma's Diamond form which was also considered immune. They were all considered immune in an era until met upon by Jean Grey because the amount of power necessary to get through their defenses was unheard of and unattainable prior to encounters with her. Jean Grey raised the bar. It has even been stated that at the pinnacle of Jean's power, no psychic shielding could hold against her telepathy.
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