Clear Example Of Copyright Infringement: Delhi High Court Grants Dynamic+ Injunction To JioHotstar Against Illegal Streaming Of India Tour Of England 2025

The High Court was considering an application whereby the plaintiff sought an order of temporary injunction restraining the Defendants and such other websites from communicating, hosting, streaming, and/or making available for viewing and downloading, without authorization, on their websites or other platforms, through the internet, the Plaintiff’s content related to India Tour of England 2025.

The Single Bench of Justice Saurabh Banerjee said, “In these circumstances, the present case appears, prima facie, to be a clear example of copyright infringement by entities such as defendant Nos.1 to 4, who are using modern technology to hide their identities while unlawfully benefiting from the plaintiff’s copyrighted works.”

Advocate Sidharth Chopra represented the Plaintiff.

Factual Background

The Plaintiff/ JioStar India Private Limited is a leading entertainment and media company engaged in the production of popular content broadcasted on its channels. The streaming platform had acquired exclusive digital media rights with respect to the India Tour of England 2025 (ITE 2025), for two years, commencing from 2025, from Culver Max Entertainment Pvt Ltd (Sony/Licensor). By virtue of the aforesaid arrangement between the plaintiff and Sony, it was agreed that the ITE 2025 matches will be made available for digital streaming on the plaintiff’s OTT platform, i.e., ‘JioHotstar’. The cause of action first arose when defendants being “rogue websites” unlawfully streamed sporting events in which the plaintiff had exclusive rights, without the authorization from the plaintiff or the owner of rights of the said sporting events, such as the Indian Premier League, 2025 (IPL).

This unlawful activity was claimed to be a continuing activity. John Doe had also been arrayed as a Defendant in the form of a generic identity, to safeguard the plaintiff’s right against infringement by any unidentified or “rogue websites” that may be discovered at a later stage. It was the Company’s claim that in cases of live sporting events such as the present ITE 2025, these “rogue websites” activate new domains/ websites and URLs just minutes before a match and later deactivate them as soon as it ends.

Reasoning

Taking note of the upcoming technology and the technological advances having their own unpredictable implications, the Bench said, “...with the immense degree of freedom enjoyed by developers and innovators globally today, all and sundry, especially those intellectual property right holders like the plaintiff herein, are prone to/ may be exposed and/ or vulnerable to the actions of the “rogue websites” herein, more so, if such right holders like the plaintiff herein, are not accorded proper protection from them.”

“Such “hydra-headed” websites, under the garb of privacy, are able to mask their registration/ contact details perfectly, making it virtually impossible to locate and contact their operators to, if necessary, demand cessation of infringing conduct”, it added.

The Bench was of the view that the the systematic, organized and intentional nature of the infringement, and the regularity and consistency with which the said content was being updated/ uploaded on the said “rogue websites” showed the extent of the violation of the rights of the plaintiff in real time. The said “rogue websites” were also employing the URL-redirection and identity masking methods, putting the plaintiff in an even more precarious condition to defend itself against their infringing actions. Noting that there was every likelihood that such “rogue websites” would continue to stream copyrighted works to the public during the ITE 2025 without authorization or license from the plaintiff, the Bench held that the plaintiff had been able to make out a prima facie case in its favour and against the defendants.

Thus the Bench restrained any person/ entity including the defendants from communicating, streaming or making available for viewing and downloading, any part of the India Tour of England 2025 matches on any electronic or digital platform. The Bench also directed blocking of certain websites and further ordered, “‘Dynamic+’ injunction is granted in favour of the plaintiff to protect its copyrighted works as soon as they are infringed/ created.” The matter has now been listed on October 13, 2025.

Cause Title: Jiostar India Pvt. Ltd. Formerly Known As Star India Pvt. Ltd. v. Https//criclk.com & Ors. (Case No.: CS(COMM) 566/2025)

Appearance

Plaintiff: Advocates Sidharth Chopra, Yatinder Garg, Priyansh Kohli

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