We missed this earlier: On December 18, 2025, the Delhi High Court granted a Dynamic+ injunction in favour of Warner Bros. Entertainment Inc., Netflix, Disney Enterprises, Apple Inc., and Crunchyroll LLC, restraining dozens of websites from infringing their copyrighted works. Justice Tejas Karia passed the order, while also directing domain name registrars (DNRs) and internet service providers (ISPs) to suspend and block access to the identified websites in India.
The case concerned allegations of large-scale online piracy of films and television programmes owned or exclusively distributed by the plaintiffs. According to the order, the plaintiffs are members of the Motion Picture Association and/or the Alliance for Creativity and Entertainment, and include companies engaged in the production and global distribution of cinematographic films and streaming content. They asserted copyright and exclusive distribution rights over a catalogue that includes titles from Warner Bros., Netflix, Disney, Apple TV+, and Crunchyroll, all of which are protected under the Copyright Act, 1957.
The plaintiffs filed the suit against 47 websites accused of making this content available for streaming and download without authorisation. In addition, they impleaded domain name registrars, internet service providers, and the Department of Telecommunications (DoT) and the Ministry of Electronics and Information Technology (MeitY) for limited purposes related to enforcement. As set out in the order, the plaintiffs issued takedown notices to the infringing websites on December 5, 2025. However, the websites allegedly continued to host the content, prompting the plaintiffs to seek urgent interim relief before the High Court.
Why did the court order a dynamic+ injunction?
Justice Tejas Karia recorded that, based on screenshots placed on record, the websites were “on real-time basis, offering for viewing and downloading the Plaintiffs’ Copyrighted Works, without their consent or a valid licence”, which resulted in financial losses to the rights-holders. Consequently, the court held that the balance of convenience lay in favour of the plaintiffs and that denying interim relief would cause them irreparable injury.
Accordingly, the judge restrained the infringing websites from “hosting, streaming, reproducing, distributing, making available to the public and/or communicating to the public” the copyrighted works. In parallel, he directed DNRs to lock and suspend the infringing domains and to file basic subscriber information relating to their operators. Further, he ordered ISPs to block access to the infringing websites in India. DoT and MeitY were arrayed for the limited purpose of issuing notifications to ISPs to facilitate such blocking.
Significantly, the court also granted a “Dynamic+ injunction”, a form of relief that allows the injunction to automatically extend to mirror, redirect, or alphanumeric variants of the infringing websites. Explaining this step, Justice Karia stated: “To keep up with the hydra-headed nature of the infringement actions of such infringing domains/websites, this Court finds it fit to grant a ‘Dynamic+ injunction’ to protect the Plaintiffs’ Copyrighted Works as soon as they are created.” He further noted “an imminent possibility of the Plaintiffs’ Copyrighted Works being uploaded on infringing websites or their newer versions immediately thereafter”, which warranted extending the order to associated domains.
Dynamic+ Injunctions And Copyright Cases
Indian courts developed dynamic injunctions as a response to a recurring enforcement problem in online copyright cases: once a court blocks a piracy website, the same operators often resurface almost immediately through mirror, redirect, or slightly modified domain names. Traditional injunctions, which required rights-holders to return to court for every new domain, proved slow and ineffective against this pattern. A key step was the Delhi High Court’s decision in UTV Software Communication Ltd. v. 1337X.to (2019), which acknowledged that static blocking orders were insufficient when infringing websites continuously changed their online identities, and issued India’s first dynamic injunction.
Subsequently, Delhi High Court judges formalised a more expansive remedy. In August 2023, Justice Pratibha Singh formulated the Dynamic+ injunction, an order that not only restrains specified infringing sites but also permits rights-holders to add mirror, redirect, or alphanumeric variants and obtain near-immediate blocking of those new domains.
Since then, courts have applied Dynamic+ orders in several copyright infringement cases. For example, the Delhi High Court granted Dynamic+ relief to major studios and platforms in 2024 and 2025 to block dozens of piracy sites. These include Warner Bros., JioStar, and DAZN. These orders typically involve domain suspension, ISP blocking, and registrar cooperation to shut down both present and future infringers.
Why This Matters
This order matters because it signals how Indian courts are recalibrating copyright enforcement for an internet ecosystem where infringement adapts faster than traditional legal remedies. By granting a Dynamic+ injunction, the Delhi High Court has effectively reduced the time lag between identifying an infringing website and disabling its successors—a delay that has long undermined the value of court-ordered blocks. Consequently, rights-holders no longer need to initiate fresh proceedings each time a blocked website reappears under a new domain, a tactic that piracy operators routinely deploy.
At the same time, the order increases the operational responsibilities of intermediaries. DNRs and ISPs must now respond quickly to evolving blocking requests, while government departments remain part of the enforcement chain. This shifts copyright disputes beyond private litigation and embeds them more deeply into India’s internet governance framework.
Therefore, the judgment illustrates the judiciary’s effort to curb large-scale online piracy without endorsing indiscriminate blocking, setting a precedent that will likely shape how future copyright disputes involving digital platforms unfold in India.
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