Delhi High Court grants Dynamic+ Injunction to JioStar against rogue websites for streaming India-England 2025 series without authorization

Dynamic+ Injunction JioStar India

Delhi High Court: A suit was filed by JioStar India Private Limited (plaintiff), formerly known as Star India Pvt. Ltd., seeking injunctive and consequential reliefs against multiple defendants, primarily rogue websites, for infringement of its exclusive digital media rights pertaining to the upcoming India Tour of England 2025. Saurabh Banerjee, J., granted an ex parte ad interim dynamic+ injunction in favour of the plaintiff, restraining the identified rogue websites as well as any other similar infringing platforms that may emerge during the live broadcast of the matches from unlawfully streaming, communicating, or making available the plaintiff’s copyrighted content.

The Court further directed the concerned Domain Name Registrars (DNRs) to block and suspend the infringing domain names and disclose full registration details of the domain holders, while Internet Service Providers (ISPs) were ordered to block access to the identified rogue websites.

The suit was filed for permanent injunction, rendition of accounts, and damages under the Copyright Act, 1957. The matter also sought immediate ex parte ad interim relief in the form of a dynamic+ injunction due to the imminent threat posed by online piracy to the plaintiff’s broadcast rights. The plaintiff is a leading entertainment and media company in India, which owns exclusive rights to various forms of content, including sports and entertainment broadcasts, through its suite of channels and OTT platforms. It had recently acquired exclusive digital streaming rights for the India Tour of England 2025 (ITE 2025) through a Sub-Licensing Agreement dated 25.05.2025 from Culver Max Entertainment Pvt. Ltd. (formerly Sony), which had itself obtained such rights from the England Cricket Board for an eight-year period (2024-2031) across multiple territories including India. These rights permitted the plaintiff to stream cricket matches on its OTT platform, JioHotstar.

The cause of action arose on 26-05-2025 when the plaintiff discovered that defendant 1 to 4—described as “rogue websites” had unlawfully streamed the Indian Premier League 2025 (IPL), to which the plaintiff had exclusive rights. The modus operandi of these rogue websites, as alleged by the plaintiff, involves activating new domains or URLs shortly before a match and deactivating them post-match to evade detection and enforcement. These rogue websites were expected to unlawfully stream the upcoming ITE 2025 cricket matches as well. Thus, anticipating recurring and real-time infringement of its rights, the plaintiff approached the Court to seek injunctive reliefs not only against known infringing websites but also against unknown and future rogue websites, termed “John Doe” or “Ashok Kumar” defendants.

To facilitate effective enforcement, the plaintiff also arrayed Domain Name Registrars (DNRs) such as Namecheap Inc., Sav.com LLC, and Tucows Domains Inc. (defendant nos.5 to 7), Internet Service Providers (ISPs) such as Airtel, Jio, Vi, etc. (defendant nos.8 to 16), and regulatory authorities such as the Department of Telecommunications (DoT) and the Ministry of Electronics and Information Technology (MEITY) (defendant nos.17 and 18). While no direct relief was sought from the government authorities, their presence was considered necessary to ensure the implementation of the orders of the Court.

The plaintiff sought a multi-pronged ex parte ad interim injunction under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, praying inter alia for the following:

(i) restraining rogue websites from unauthorized streaming of ITE 2025 content;

(ii) directing DNRs to suspend domain names of infringing websites and disclose registrant information;

(iii) directing ISPs to block access to infringing websites;

(iv) mandating DoT and MEITY to instruct ISPs accordingly; and

(v) granting a ‘dynamic+’ injunction to enable real-time blocking of newly discovered infringing websites during live events.

The Court noted that the plaintiff had made a prima facie case for infringement, having already experienced unauthorized streaming of its IPL 2025 content by rogue websites. The Court also recognized the highly organized and technologically adaptive conduct of such infringers, highlighting that they often deploy “hydra-headed” tactics, rapid creation of mirror or redirect websites, use of masked identities, and URL-redirection to continue the infringing activity. It emphasized the evolving challenges of enforcing intellectual property rights in the digital domain and affirmed the need to adopt equally adaptive judicial mechanisms.

The Court analyzed the plaintiff’s entitlement under Section 37 of the Copyright Act, 1957 and acknowledged the legal evolution permitting ‘dynamic+’ injunctions in intellectual property enforcement. He referenced precedents including the Applause Entertainment v. Meta Platforms Inc., 2023 SCC OnLine Bom 1034 and Universal City Studios LLC v. Dotmovies, 2023 SCC OnLine Del 4955 which permitted real-time blocking and expansion of injunctions to newly emerging infringing websites.

Therefore, the Court recognizing the immediacy and scale of harm, granted the following reliefs on an ex parte ad interim basis:

(a) restrained all defendants, including future rogue entities, from unauthorized streaming of ITE 2025 matches;

(b) directed DNRs (defendants 5 to 7) to block specific rogue websites and disclose complete registrant information within 72 hours;

(c) directed ISPs (defendants 8 to 16) to block access to the identified websites;

(d) granted the plaintiff liberty to notify additional infringing websites during the live telecast of matches and obtain blocking orders on a real-time basis; and

(e) mandated DoT and MEITY to ensure compliance by issuing necessary directives to the ISPs.

[JioStar India Pvt. Ltd. v. https//criclk.com, 2025 SCC OnLine Del 4608, decided on 29-05-2025]


Advocates who appeared in this case :

Mr. Sidharth Chopra, Mr. Yatinder Garg and Mr. Priyansh Kohli, Advocates for plaintiff

Must Watch

maintenance to second wife

bail in false pretext of marriage

right to procreate of convict

Join the discussion

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.