Isabella Mariam

The High Court of Madras, Single Bench of Justice Senthilkumar Ramamoorthy has issued an ad interim injunction restraining more than 30 internet service providers, and certain cable television operators, from unlawfully streaming or otherwise making available the upcoming Hindi film “Happy Patel Khatarnak Jasoos”. The direction followed a plea by the producer alleging apprehended infringement of its copyright in the cinematographic work ahead of the film’s scheduled release on 16.01.2026. The producer placed a CBFC certificate as prima facie material of ownership. Noting that irreparable injury was likely unless interim protection was granted, the Court allowed the requested restraint, subject to the producer indemnifying the respondents if any legitimate business interests are affected. The injunction will remain in force until 02.02.2026.

The proceedings arose from a commercial suit instituted seeking preventive reliefs in respect of apprehended infringement of copyright in a cinematographic film. The applicant asserted ownership of copyright in the film and sought interim protection against unauthorised dissemination prior to its scheduled theatrical release. Two interlocutory applications were filed seeking ad interim injunctions against internet service providers and cable television operators who were arrayed as respondents in the respective applications.

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The applicant relied upon certification issued by the Central Board of Film Certification indicating the applicant as the producer of the film. Promotional material placed on record disclosed that the film was scheduled for release on 16 January 2026. The apprehension raised was that unauthorised online streaming, transmission, or cable broadcast could occur before or upon release, resulting in infringement of copyright.

The reliefs sought were expansive in nature and directed against multiple entities engaged in providing internet, broadband, and cable television services. The applications were placed before the Commercial Division for consideration of interim protection pending issuance of notice.

The statutory framework governing the grant of interim injunctions under the Code of Civil Procedure was invoked, including compliance requirements under Order XXXIX Rule 3 CPC, in addition to the rights asserted under copyright law.

The Court examined the nature of the relief sought and the material placed in support of the applicant’s claim. With respect to ownership of copyright, the Court recorded that “as prima facie evidence of the plaintiff’s ownership of copyright, the plaintiff has submitted the CBFC certificate mentioning the name of the plaintiff as the producer.”

While considering the urgency of the request, the Court noted the proximity of the scheduled release date and observed that “the promotional material reveals that the movie is slated for release on 16.01.2026.” The Court proceeded to assess the potential consequences of denying interim protection at the pre-release stage.

On the aspect of irreparable harm, the Court stated that “in matters of this nature, it is likely that irreparable injury would be caused unless ad interim relief is granted.” The Court acknowledged that unauthorised dissemination, once it occurs, may not be capable of being effectively remedied by subsequent relief.

At the same time, the Court recorded the competing consideration arising from the breadth of the relief sought against a large number of service providers. It observed that “in view of the expansive nature of the relief claimed, it is possible that the legitimate business interest of one or more respondents may be affected.”

Balancing these considerations, the Court found it appropriate to condition the grant of interim protection. It recorded that “therefore, the plaintiff shall indemnify in respect thereof.” The requirement of indemnification was imposed as a safeguard against potential prejudice to the respondents arising from the interim restraint.

The Court thus formed a prima facie view that interim protection was warranted, subject to compliance with procedural safeguards and conditions imposed.

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The Court directed that “subject to the above condition, orders of ad interim injunction as prayed for are granted until 02.02.2026. Issue notice to the respondents returnable on 02.02.2026. Private notice is also permitted. The applicant shall comply with Order XXXIX Rule 3 CPC.”

Advocates Representing the Parties

For the Petitioners: Mr. T. Pandiyan, Advocate

Case Title: Aamir Khan Productions Pvt. Ltd. v. Internet Service Providers & Cable Operators
Case Number: O.A. Nos. 27 and 28 of 2026 in C.S. (Comm. Div.) No. 11 of 2026
Bench: Justice Senthilkumar Ramamoorthy