Piracy Must Be Stopped Before the Leak Begins: Delhi High Court Grants ‘Dynamic+’ Injunction to Protect ‘Jolly LLB 3’ from Online Infringement

“The Plaintiff shall be entitled to seek real-time blocking of infringing websites even during the release window. Any delay will cause irreparable harm.” — Delhi High Court passed a significant ex-parte interim injunction order, restraining over two dozen rogue websites and directing domain name registrars, ISPs, and government departments to block unauthorized dissemination of the upcoming film ‘Jolly LLB 3’. The order reflects the Court’s growing concern with the rampant digital piracy ecosystem and its evolving modus operandi.

In a precedent that reinforces judicial adaptability in the face of technological threats, the Court invoked the doctrine of ‘Dynamic+ Injunction’, a step beyond traditional orders, aimed at preemptive blocking of existing and future infringing websites.

“In the Digital Age, Injunctions Must Evolve with the Infringers”: Court Recognizes Threat of Piracy in Real-Time

The Court observed that piracy today is no longer a post-release event. The speed with which films are leaked, uploaded, and distributed via rogue domains requires judicial action before the damage is done. Citing the Supreme Court’s decision in Yamini Manohar v. T.K.D. Krithi and its own ruling in Universal City Studios LLC v. Dotmovies.baby, the Court declared:

“Copyright in future works comes into existence immediately upon the work being created. Plaintiffs may not be able to approach the Court for every film or series. Hence, injunctions must be dynamic, not only for the past but also for works created during litigation.”

The Plaintiff, JioStar India Pvt. Ltd., a media and production company, had approached the Court seeking urgent interim relief to prevent online piracy of its unreleased film ‘Jolly LLB 3’, slated for theatrical release on 19 September 2025. The company contended that platforms such as vegamovies.yachts, filmyzilla20.com, downloadhub.cash, and others are known hubs of unauthorized streaming and downloading of copyrighted works.

Allegations: A Sophisticated Web of Digital Piracy

JioStar submitted that: “These Websites engage in communicating to the public, streaming, and making available Plaintiff’s copyright-protected content without authorization. Their services are not geo-restricted and are accessible in Delhi and across India.”

To prevent further exploitation, JioStar had listed 24 rogue websites, 10 domain name registrars, 9 internet service providers, and key government departments including DoT and MeitY as parties in the suit. Counsel argued that piracy at the time of release can cause severe financial losses, nullifying years of creative and monetary investment.

Judicial Measures: Swift, Pre-Emptive, Real-Time Enforcement

Justice Tejas Karia, while granting the reliefs, emphasized that the balance of convenience lay entirely in favor of the Plaintiff. He reasoned that the unregulated dissemination of the film would render the Plaintiff’s exclusive rights “nugatory.” Therefore, the Court issued the following binding directions:

“Defendant Nos. 1 to 24 (websites) and persons acting on their behalf are restrained from communicating, hosting, streaming, or making available the Film, ‘Jolly LLB 3’, on any digital platform.”

“Domain Name Registrars (Defendant Nos. 25 to 34) shall block and disable the domain names of these websites within 72 hours.”

“ISPs (Defendant Nos. 35 to 43) and government bodies (DoT, MeitY) are to ensure that access to the infringing websites is blocked immediately upon notification.”

“Future websites discovered by the Plaintiff as infringing shall also be disabled in real-time upon intimation.”

Sealing the Loopholes: Disclosure of Pirate Infrastructure Mandated

In a novel direction aimed at piercing the anonymity of digital piracy, the Court ordered that all Domain Name Registrars must file affidavits in sealed cover disclosing:

• Names, addresses, phone numbers, and IPs of registrants behind the pirate domains.

• Mode and details of payments used for registration.

These measures reflect an intent to trace the monetary and digital trail of infringers, not just block access.

“Judicial Protection Must Match the Speed of Online Infringement”

Justice Karia remarked: “Any delay in blocking the websites would, in fact, result in considerable pecuniary loss and irreparable violation of the copyright of the Plaintiff.”

The Court underscored that real-time orders are now indispensable in light of the technological dexterity of rogue platforms, which frequently change domain names or mirror sites within hours of being blocked.

To manage this, the Plaintiff was also granted liberty to file affidavits disclosing newly discovered rogue sites and seek impleadment in an ongoing manner.

Safeguard Against Overreach: Innocent Sites Can Approach Court

Acknowledging the possibility of collateral damage to non-infringing websites, the Court inserted a protective clause:

“If any website, which is not primarily an infringing website, is blocked pursuant to this Order, it may approach the Court by giving an undertaking that it will not disseminate the copyrighted content.”

Such balance ensures that free speech and legitimate business interests are not unduly suppressed, even as piracy is targeted aggressively.

A Landmark Step in Indian Copyright Enforcement

This judgment is a significant evolution in Indian IP jurisprudence, as it reaffirms that “judicial relief must not remain static in the face of dynamic digital threats.” The use of ‘Dynamic+ Injunctions’, covering present and future works, offers a real-time legal shield to copyright holders, especially in the entertainment sector.

Date of Decision: 12 September 2025