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Introduction

In today’s digital world, the entertainment industry faces persistent challenges from online piracy. The ease with which copyrighted content can be accessed and shared illegally has prompted courts to adopt more robust legal mechanisms to protect intellectual property. The Delhi High Court’s decision in Jiostar India Pvt. Ltd. v. Vegamovies.yachts & Ors., CS(COMM) 977/2025, delivered on 12 September 2025, is a significant development in this regard. The case involved the anticipated release of the Bollywood film Jolly LLB 3 and a network of rogue websites accused of hosting and streaming pirated content. The Court granted a wide-ranging interim injunction, including dynamic and real-time blocking orders, to safeguard the film’s release and the rights of its producers.

Fact of the Case

Jiostar India Pvt. Ltd., a media and film production company, had commissioned Kangra Talkies Pvt. Ltd. to develop and produce the film Jolly LLB 3. On 21 August 2025, Kangra Talkies confirmed in writing that Jiostar was the sole and exclusive owner of all rights related to the film, including intellectual property, distribution, and digital broadcasting rights. The film was scheduled for theatrical release on 19 September 2025.

Anticipating the risk of piracy, Jiostar filed a commercial suit before the Delhi High Court seeking a permanent injunction against 24 websites known for hosting and streaming pirated content. The suit also included domain name registrars (Defendant Nos. 25–34), internet service providers (Defendant Nos. 35–43), and government authorities (Defendant Nos. 44–45) to ensure compliance with any court orders. The Plaintiff submitted that the websites were accessible across India, including Delhi, and posed a serious threat of unauthorized dissemination of the film. Several interim applications were filed seeking urgent relief, including exemption from procedural requirements and permission to file additional documents.

Argument in Favour

The Plaintiff argued that the Defendants were engaged in illegal activities by hosting and streaming copyrighted content without authorization, which amounted to copyright infringement under the Copyright Act, 1957. The Plaintiff emphasized that the websites were operational within the Court’s jurisdiction and were not geo-restricted, making them accessible to users across India. It was further contended that internet service providers acted as gateways, enabling access to infringing websites. If the websites were not blocked immediately, the Plaintiff would suffer irreparable harm, especially given the imminent release of the film.

The Plaintiff highlighted the recurring nature of piracy and the evasive tactics used by rogue websites, which often change domain names to avoid detection. To support its claim, the Plaintiff relied on the Delhi High Court’s decision in Universal City Studios LLC v. Dotmovies.baby, 2023: DHC:5842, where the Court granted a “Dynamic+” injunction. This type of injunction protects not only the current work, but also future works created during the pendency of the suit. The Plaintiff argued that such relief was necessary to effectively combat piracy. Additionally, the Plaintiff cited Star India Pvt. Ltd. v. moviesverse.ac & Ors., CS(COMM) 87 of 2023, where the Court extended injunctions to cover newly discovered rogue websites, recognizing the evolving nature of online infringement.

Argument Against

The Defendant Nos. 31 and 34, representing domain name registrars, objected to the Plaintiff’s request for real-time blocking. They argued that the film was not a live event and therefore did not warrant real-time enforcement measures. They questioned the practicality and necessity of granting such broad relief before the film’s release, suggesting that the Plaintiff’s request was disproportionate to the nature of the content involved.

Court’s Decision

The Delhi High Court found that the Plaintiff had established a strong prima facie case for the grant of an ex-parte ad-interim injunction. The Court recognized Jiostar as the rightful owner of the film and its associated rights. It held that the balance of convenience favored the Plaintiff and that failure to grant immediate relief would result in irreparable harm. The Court issued a dynamic injunction, allowing the Plaintiff to block newly discovered infringing websites during the pendency of the suit.

The Court granted exemption from pre-institution mediation under Section 12A of the Commercial Courts Act, 2015, citing urgency and the need for interim relief. This exemption was supported by the Supreme Court’s decision in Yamini Manohar v. T.K.D. Krithi, 2023 SCC OnLine SC 1382, which clarified that mediation can be bypassed in cases requiring urgent judicial intervention. The Court also invoked Order XXXIX Rule 1 and 2 of the Civil Procedure Code (CPC), which empower courts to grant temporary injunctions to prevent irreparable harm. These provisions formed the basis for the dynamic injunction issued in this case.

Further, the Court allowed exemption from payment of court fees under Section 149 of the CPC, granting the Plaintiff two weeks to comply. It also exempted the Plaintiff from the requirement of serving notice to government authorities under Section 80 of the CPC, due to the urgency of the matter. Under Order XI Rule 1(4) of the CPC, as applicable to commercial suits, the Plaintiff was permitted to file additional documents to support its claims.

The Court cited Universal City Studios LLC v. Dotmovies.baby to justify granting a “Dynamic+” injunction, which protects future works and allows real-time blocking. It also referred to Star India Pvt. Ltd. v. moviesverse.ac & Ors. to support the need for flexible enforcement mechanisms that can adapt to the evasive tactics of rogue websites. The Supreme Court’s ruling in Yamini Manohar v. T.K.D. Krithi was used to validate the exemption from pre-institution mediation.

Directions Issued by the Court

The Court issued several directions to ensure effective enforcement of its order. Defendant Nos. 1–24, comprising the infringing websites, were restrained from hosting, streaming, or making the film Jolly LLB 3 available without authorization. Defendant Nos. 25–34, representing domain name registrars, were ordered to suspend, block, and deactivate the domain names of infringing websites within 72 hours of receiving the order. They were also required to disclose registrant details in a sealed affidavit.

Defendant Nos. 35–43, the internet service providers, were directed to block access to the infringing websites and any newly discovered domains during the proceedings. Defendant Nos. 44–45, the government authorities, were instructed to issue notifications to ISPs to block access to infringing websites and any additional domains identified by the Plaintiff.

The Plaintiff was granted liberty from notifying authorities of any new infringing websites before or during the film’s release. Upon notification, ISPs and government authorities were required to act immediately to block access. The Plaintiff was also directed to file affidavits detailing newly discovered websites and submit applications for impleadment. If any non-infringing website was mistakenly blocked, it could approach the Court for modification of the injunction.

Conclusion

The Delhi High Court’s decision in Jiostar India v. Vegamovies marks an advancement in the legal framework for combating online piracy. By granting a dynamic and real-time injunction, the Court acknowledged the evolving nature of digital infringement and the need for swift enforcement. The judgment provides a strong legal foundation for content creators to protect their work and sets a precedent for future cases involving unauthorized dissemination of copyrighted material. For producers and media houses, this ruling offers a powerful tool to safeguard their investments and uphold the integrity of their creative content.