Delhi High Court Grants Dynamic+ Injunction Against Rogue Websites to Protect Copyrighted Content of Global Entertainment Companies Including Universal Studios
Sanchayita Lahkar
The High Court of Delhi, Single Bench of Justice Manmeet Pritam Singh Arora ordered a sweeping ad-interim injunction restraining 106 identified rogue websites and related mirror or redirect domains from hosting, streaming, reproducing, or distributing copyrighted films and shows of leading global entertainment companies, including members of the Motion Picture Association and the Copyright Overseas Promotion Association. The Court further directed domain registrars, internet service providers, and government authorities such as the Department of Telecommunications and the Ministry of Electronics and Information Technology to block access to these infringing websites and to furnish registrant details, granting the plaintiffs a “Dynamic+” injunction to address evolving piracy practices.
The plaintiffs, comprising major global entertainment companies and members of the Motion Picture Association along with the Copyright Overseas Promotion Association, initiated proceedings before the High Court of Delhi against alleged large-scale online piracy of their copyrighted cinematograph films and other audiovisual content.
They alleged that a group of websites, identified as 106 rogue platforms, were engaged in unauthorized hosting, streaming, and distribution of their copyrighted works. According to the plaintiffs, these websites operated without any license or authorization and continued to make infringing content available to the public, often shifting to mirror, redirect, or alphanumeric domains to evade enforcement.
The plaintiffs submitted that the unlawful activities of these websites caused significant economic harm by undermining legitimate distribution channels for their films and other content. They presented materials including affidavits, technical reports, screenshots of webpages, and URLs showing that their copyrighted films and programs were being made available without authorization. They further highlighted that the operators of these websites earned revenue through advertisements and other means, despite engaging in infringing activities.
The plaintiffs contended that the continuous and widespread infringement violated their exclusive rights as copyright owners under the Copyright Act, 1957. They relied on the statutory provisions that protect reproduction, distribution, public performance, and communication to the public of copyrighted works.
They asserted that the activities of these websites not only infringed their legal rights but also hindered legitimate business operations by diverting viewers from lawful platforms. The plaintiffs argued that because the operators were often anonymous and operated across jurisdictions, conventional legal remedies were inadequate unless preventive measures were adopted.
To substantiate their claims, the plaintiffs placed on record evidence of repeated infringement, the structure and functioning of the rogue websites, and details demonstrating how such platforms were facilitating large-scale unauthorized access to their works. They stressed the need for effective legal intervention to curb online piracy and protect their rights under the Copyright Act.
The Court stated, “Based on the averments made in the plaint, the Plaintiffs have established themselves as the owner of their works in the original content motion pictures/cinematographic films.” The Court further recorded that a prima facie case, balance of convenience, and the likelihood of irreparable harm were in favour of the plaintiffs, observing, “A prima facie case is made out in favour of the Plaintiffs and balance of convenience is also in its favour. Further, irreparable harm or injury would be caused to the Plaintiffs if an ad-interim injunction order is not passed.”
Justice Arora referred to the 2019 UTV Software Communication Ltd. judgment, noting that it provided legal justification for extending injunctions to mirror or redirect websites that perpetuate infringement by evading blocking measures. The Court acknowledged that the infringing platforms engaged in systematic reproduction, communication, and facilitation of pirated content in violation of the Copyright Act.
The order also discussed the liability of various classes of defendants. Domain Name Registrants (Defendant Nos. 107–129) were held responsible for suspending and locking the infringing domains and providing KYC and registration details. Internet Service Providers (Defendant Nos. 130–138) were directed to block access to the rogue domains within 72 hours. Government departments (DOT and MEITY) were tasked with issuing notifications to telecom operators and ISPs to ensure enforcement of the blocking orders. The Court observed that these directions were necessary to curb the hydra-headed nature of online piracy, wherein blocked websites often reappear under new domain names.
Justice Arora introduced the concept of a “Dynamic+ injunction” to counter emerging mirror and redirect sites. The Court noted, “To keep up with the hydra-headed nature of the infringement actions of such infringing domains/websites, this Court finds it fit to grant a ‘Dynamic+ injunction’ to protect copyrighted works as soon as they are created.” This approach allows plaintiffs to extend injunctions against newly identified infringing websites by filing a simple application under Order I Rule 10 of the CPC, without initiating a separate suit.
The Court directed that “Defendant Nos. 1 to 106… are restrained from, in any manner hosting, streaming, reproducing, distributing, making available to the public and/or communicating to the public, or facilitating the same, on their websites, through the internet in any manner whatsoever, any cinematograph work/content/programme/show in relation to which Plaintiffs have copyright or exclusive distribution rights.”
The Domain Name Registrants were ordered to lock and suspend the identified domains and provide complete registrant details, including KYC, credit card, and mobile information, to the plaintiffs within 72 hours of receiving the order. Similarly, the Internet Service Providers were instructed to block access to all 106 websites and related mirror or redirect domains. DOT and MEITY were directed to issue notifications requiring ISPs and telecom providers to block access to the infringing domains within 72 hours.
The Court clarified that websites not primarily engaged in infringement could approach it with an affidavit to seek modification of the injunction if they demonstrated an intention not to host unauthorized material. The plaintiffs were authorized to implead additional infringing domains through impleadment applications to extend the injunction as new mirror sites emerged.
Also Read: Delhi High Court Orders Fresh Review of Patent Bid for Zero-Liquid-Discharge Recovery Process
The Court ordered Defendant Nos. 107 to 140 to file compliance affidavits within two weeks confirming execution of the directions. Furthermore, the Court directed the plaintiffs to e-file a “convenience volume” and an “Evidence Key” illustrating the infringing activities of the defendants. The matter was listed before the Joint Registrar for completion of service and pleadings on 10 November 2025 and before the Court for further hearing on 20 March 2026.
Advocates Representing the Parties:
For the Plaintiffs: Mr. Sidharth Chopra, Ms. Suhasini Raina, Ms. Mehr Sidhu, Mr. Pushpit Ghost, and Mr. Raghav Goyal, Advocates.
For the Defendants: Mr. Yash Raj, Advocate, for Defendant Nos. 113 and 115.
Case Title: Universal City Studios Productions LLLP & Ors. v. Isaidub.spot & Ors.
Case Number: CS(COMM) 1009/2025
Bench: Justice Manmeet Pritam Singh Arora
Comment / Reply From
Related Posts
Stay Connected
Newsletter
Subscribe to our mailing list to get the new updates!
