INTRODUCTION
In a landmark decision for the petition filed CS (COMM) 1361/2025 which reinforced intellectual property rights protection in the digital ecosystem, the Delhi High Court in the case of Warner Bros. Entertainment., Inc. & Ors vs Animesugez.to & Ors. on 18th December 2025, wherein, a new legal innovation was made by the Delhi High Court in the form of “Dynamic+ injunction” which restraints various websites from illegally hosting and streaming popular copyrighted entertainment content including the acclaimed series such as Stranger Things, Friends, Batman, Squid Game, The Jungle Book and numerous other films and shows. A Single Bench consisting of Hon’ble Justice Tejas Karia recognized the unprecedented scale in which digital piracy and the hydra-headed tactics are being employed by the rogue websites. This led to the authorization of an innovative judicial mechanism which extends protection not merely to presently known infringing platforms but also to future iterations, mirror sites, and technological variations that may emerge in real-time. The court emphasized that swift and adaptive judicial intervention has become imperative to combat the sophisticated ecosystem of online piracy that systematically undermines the legitimate digital distribution framework and causes substantial financial losses to global entertainment corporations.
BACKGROUND
The case originated from a suit filed by members of the Motion Picture Association and the Alliance for Creativity and Entertainment—including major global entertainment companies such as Warner Bros. Entertainment Inc., Netflix, Apple Inc., The Walt Disney Company, and Crunchyroll who sought for a permanent injunction and ancillary reliefs against 47 identified rogue websites engaged in unauthorized streaming and downloading of copyrighted cinematographic works. The plaintiffs alleged that despite the issuance of a notice for formal take-down, the defendant’s websites continued with their infringing activities with impunity, enabling real-time streaming and downloading of protected content without any authorization or valid license. The plaintiffs argued that they hold leg ownership and exclusive copyright vis-à-vis section 14 of Copyright Act, 1957. The flagrant violation of section 51 and 55 of the Copyright Act of 1957 by the defendants as submitted by the counsel representing the plaintiffs is resulting in significant commercial and reputational harm, which undermined the growth of legitimate online distribution system being held by the plaintiffs.
KEY POINTS
The Delhi High Court observed that the Plaintiffs had established a strong prima facie case for granting of an ex-parte ad-interim injunction and that the balance of convenience lays conclusively in their favor against the infringing websites.
- Justice Tejas Karia noted that the infringing websites were offering the owned corporate works of plaintiffs for viewing and downloading in real time without authorization or valid license thereby violating exclusive copyright rights wasted in the plaintiffs under Copyright Act, 1957.
- The Court held an observation that unauthorized misuse of copyrighted content could lead to significant and irreparable financial losses for the plaintiffs such piracy directly competed with legitimate distribution channels and losses for revenue streams of authorized platforms. The Court came to the opinion that without immediate injunctive relief, the plaintiff would suffer losses that could not be adequately compensated through monetary damages alone.
- The Court also mentioned in its judgment such websites, employing sophisticated technologies and adoptive tactics such as frequent resurging of new domain names, mirroring of sites and redirection links, all of which evade the scope of traditional static injunctions and necessitating dynamic judicial mechanisms.
- To address the evolving and recurring nature of digital piracy, Justice Karia observed that a “Dynamic+ injunction” was the appropriate remedy, permitting the Plaintiffs to notify newly discovered infringing websites to the Court’s designated nodal officers or Internet Service Providers for real-time blocking without requiring fresh suits or separate applications.
RECENT DEVELOPMENTS
The judgment pronounced by the Delhi High Court was widely recognized by intellectual property advocates, content creators and digital rights organizations as a pivotal precedent in battling online piracy. Domain Name Registrars and Internet Service Providers have already commenced taking necessary steps with the 72- hour directives to lock, suspend and block access to identified infringing websites. The plaintiffs have been authorized to implement mirror, redirect, and variant websites without requiring separate proceedings, provided such websites are demonstratively associated with the primary infringing platforms purposes such as branding, identity or content sourcing.
CONCLUSION
The Delhi High Court’s verdict to promulgate and grant a “Dynamic + injunction” is an integral occurrence in digital copyright jurisprudence in India. By providing recognition to adaptive and technologically sophisticated tactics employed in modern piracy networks which the traditional static injunctions prove to be inadequate to fight against, the Court has affirmed the judiciary’s commitment to employ evolving legal remedies in consonance with growing challenges. The judgment provides that copyright protection attaches the very moment of existence of creative expression and judicial mechanisms must adopt with equal amount of dynamism to prevent severe commercial and creative loss. The order concurrently protects the legitimate digital distribution ecosystem while safeguarding that enforcement mechanisms do not arbitrarily block non-infringing platforms, thereby achieving a balanced approach to intellectual property protection in the digital age.
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WRITTEN BY: KRISHNA KOUSHIK
