Delhi High Court Cracks Down On Online Piracy Of Kannappa Film | Orders Meta And X To Take Down Infringing Content And Block Rogue URLs
Sanchayita Lahkar
The High Court of Delhi Single Bench of Justice Jyoti Singh granted an ex parte ad-interim injunction directing Meta Platforms Inc. and X Corp. to take down infringing URLs hosting unauthorized content of a recently released film. The order was issued in response to a civil commercial suit initiated by a film production company that sought urgent relief to restrain the unauthorised dissemination of its copyrighted work. Recognizing the urgency and the potential for irreparable harm, the Court permitted the plaintiff to bypass pre-institution mediation and advance service requirements. The Court also allowed time for filing the requisite court fee and directed service of summons to the remaining defendants. The plaintiff was permitted to proceed against unidentified parties hosting pirated content, commonly referred to as "John Doe" defendants. The Court noted the plaintiff’s ownership of the film and its statutory rights under the Copyright Act, 1957, and observed that the balance of convenience favoured interim protection. Consequently, the Court ordered intermediary platforms to disable the specific URLs identified by the plaintiff and reserved further hearing on the injunction application.
The plaintiff in the suit is Twenty-Four Frames Factory Private Limited, a film production house founded by Dr. M. Mohan Babu. The production house develops and produces cinematographic works, including films, and employs a team of creative professionals, filmmakers, and content creators. The suit was filed before the Delhi High Court as a commercial suit under the Commercial Courts Act, 2015, and included applications under various provisions of the Civil Procedure Code (CPC).
The plaintiff filed an application under Section 12-A of the Commercial Courts Act, 2015 read with Section 151 of the CPC seeking exemption from pre-institution mediation. The plaintiff argued that urgent relief was required and relied upon precedents, namely Yamini Manohar v. T.K.D. Keerthi, (2024) 5 SCC 815, and Chandra Kishore Chaurasia v. RA Perfumery Works Private Ltd., 2022 SCC OnLine Del 3529. The Court accepted this argument and granted the exemption.
A second application was filed under Section 149 of the CPC, seeking an extension of time for filing the court fee. The Court allowed the application and permitted the plaintiff to file the requisite court fee within four weeks.
A third application under Section 151 CPC sought exemption from advance service to Defendants No. 1 and 7 to 14. Given the urgent nature of relief sought, the Court exempted the plaintiff from advance service to those defendants.
The main suit was registered as CS(COMM) 713/2025. At the outset of proceedings, the plaintiff sought deletion of Defendant No. 3 from the array of parties, which the Court allowed. The plaintiff was directed to file an amended memo of parties within two weeks.
The Court issued summons in the suit, with counsels for Defendants No. 2, 5, and 6 accepting service. These defendants were directed to file written statements within 30 days of receipt of summons, accompanied by affidavits of admission and denial of documents filed by the plaintiff. The plaintiff was given 30 days thereafter to file replications, along with affidavits responding to the documents filed by these defendants.
Summons were directed to be issued to the remaining defendants through all permissible modes, returnable before the Joint Registrar on 26.09.2025. Written statements by these defendants were also to be filed within 30 days of receipt of summons. Replications and affidavits from the plaintiff were permitted thereafter. The Court directed that any inspection of documents be conducted in accordance with the Delhi High Court (Original Side) Rules, 2018. The Joint Registrar was assigned the responsibility of conducting admission/denial of documents and marking of exhibits.
The plaintiff also filed an interlocutory application under Order XXXIX Rules 1 and 2 read with Section 151 of the CPC seeking an ex parte ad-interim injunction. The plaintiff’s case rested on its claim of copyright ownership over the film titled Kannappa, which it described as a major production based on religious folklore about Lord Shiva and his devoted follower. The plaintiff alleged that substantial investment had been made in the production of the film, including advanced graphic techniques and high-end technology.
According to the plaintiff, the film had been licensed to various distributors and aggregators for streaming and related exploitation rights. Despite this, the plaintiff contended that the defendants, including social media platforms (Defendants No. 2 to 4) and rogue websites, were hosting pirated content, including full films, clips, and reels, causing commercial and reputational loss to the plaintiff. The plaintiff submitted that its anti-piracy agency had identified 1776 infringing links on Meta platforms, out of which only 191 had been removed as of the date of the suit.
The plaintiff contended that such acts of copyright infringement violated its exclusive rights under Sections 13(b) and 14(d) of the Copyright Act, 1957. It further submitted that the infringement impacted contractual obligations with licensed distributors and caused irreparable harm.
Learned counsel appearing for Defendant No. 2 submitted that 191 infringing links had already been removed and the defendant would comply with any directions issued by the Court. The suit sought dynamic injunctions to block infringing content, revoke rogue domain registrations, and disclose registrant details for further proceedings and claims for damages.
Justice Jyoti Singh observed that "Plaintiff has made out a prima facie case for grant of ex parte ad-interim injunction". The Court stated that "Balance of convenience lies in favour of the Plaintiff and it is likely to suffer irreparable harm in case the injunction, as prayed for, is not granted."
Referring to the plaintiff’s submissions on the ownership of copyright, the Court recorded that "Plaintiff is stated to be a production house established by Dr. M. Mohan Babu, a renowned actor, producer and educationist", and that "Plaintiff houses numerous creative visionaries, seasoned film makers and content creators to produce one of the finest cinematographic films."
On the nature of the work produced, the Court noted: "Plaintiff produced the film Kannappa which is one of the most ambitious projects of Mr. Babu and the film is based on religious folkfare about Lord Shiva and his devoted follower, capturing the journey of the follower and his transformation in exploring spirituality."
Regarding the ownership of copyright and exploitation rights, the Court recorded: "It is Plaintiff’s case that by virtue of Sections 13(b) and 14(d) of the Copyright Act, 1957, Plaintiff is the owner of the copyright in the film and thus has an exclusive right to exploit the same."
On the infringing activities, the Court stated: "Defendants including social media platforms such as Defendants No. 2 to 4 and rogue websites as impleaded in the suit are engaging in flagrant copyright infringement by hosting and sharing pirated content including full movie, reels and clips." The Court further noted: "This unauthorized activity, amplified by rapid viewership in the millions, undermines and adversely impacts Plaintiff’s commercial interests, disrupts contractual obligations with distributors and causes irreparable reputational harm to the Plaintiff."
Recording the plaintiff’s evidence, the Court observed: "An anti-piracy agency representing the Plaintiff has reported 1776 infringing links on Meta platforms of which only 191 have so far been removed."
The Court acknowledged Defendant No. 2's position: "Learned counsel for Defendant No. 2, appearing on advance copy of the application submits that as per Plaintiff’s own showing 191 infringing links have been removed and the answering Defendant is ready to abide by any further direction passed by this Court."
Based on these submissions and the material presented, the Court concluded that interim relief was warranted.
Accordingly, the Court passed the following interim directions:
"Defendant No. 2/Meta Platforms Inc. is directed to take down and disable the URLs hosting the infringing videos on Instagram and Facebook (mentioned at pages 176 to 212)."
"Defendant No. 4/X Corp. shall take down and disable the URL mentioned at page 213, in accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021."
"Plaintiff shall comply with provisions of Order XXXIX Rule 3 CPC qua Defendant No. 4 within one week from today."
Advocates Representing the Parties:
For the Plaintiff: Ms. Neha Khanduri and Mr. Achal Mittal, Advocates
For the Defendants: Mr. Varun Pathak, Mr. Akhil Shandilya and Mr. Mrityunjay Roy, Advocates; Ms. Nidhi Raman, CGSC with Mr. Arnav Mittal and Mr. Om Ram, Advocate
Case Title: Twenty-Four Frames Factory Private Limited v. John Doe & Ors.
Case Number: CS(COMM) 713/2025
Bench: Justice Jyoti Singh
