Battling Hydra-Headed Piracy: JioStar Secures Dynamic+ Injunction From Delhi High Court

Introduction

The digital revolution has propelled sports and entertainment into unprecedented popularity online, but it has also spawned a parallel ecosystem of "hydra-headed" piracy, websites and apps that replicate, redirect, and re-emerge to stream copyrighted content in seconds. Recognizing this challenge, the Indian courts have increasingly deployed innovative remedies, dynamic injunctions, and more recently, superlative injunctions, to combat issues of real-time infringement.

The Hon'ble Delhi High Court's ex parte Dynamic+ injunction inJiostar India Pvt. Ltd. v. criclk.com & Ors.¹, is the latest milestone in this evolving jurisprudence, building upon a foundation of landmark cases.

Facts of the Case

JioStar, (Plaintiff) through a sub-licensing agreement with Sony (Culver Max Entertainment), the official rights holder authorized by the England and Wales Cricket Board (ECB), holds exclusive digital rights for the India vs England 2025 cricket series.

The Plaintiff moved to the Hon'ble Delhi High Court, alleging that several rogue websites (including [https://criclk.com] (https://criclk.com) and other unidentified parties) had previously engaged in unauthorized streaming of IPL 2025 matches, thereby creating a credible and imminent threat of repetition during the upcoming tour. The Plaintiff sought urgent relief to preemptively curb infringing activity.

Hon'ble Court's Observations and Findings

Justice Saurabh Banerjee delivered a comprehensive ex parte ad-interim order, recognising the sophisticated and evasive techniques adopted by infringing websites, including:

• URL redirection
• Identity masking
• Hydra-headed replication of domains

The Bench noted that the systematic, organized, and intentional nature of infringement, along with real-time updates of pirated content, illustrated the scale of violation and the inability of traditional remedies to keep pace with the infringing conduct.

Further, the Court observed that domain registrants often cloak their identity under the guise of privacy, making it practically impossible to serve them notices or initiate standard takedown procedures. This "dangerous edge of technology," as described by the Hon'ble judge, warranted urgent judicial intervention to prevent "serious and irreparable harm" to the plaintiff's rights.

Reliefs Granted

The Court granted the following reliefs:

1. Ex parte ad interim injunction restraining:
   • The identified defendants
   • John Doe parties (unnamed and unknown)
   • Any other person/entity from streaming, downloading, or making available any part of the India vs England 2025 series
2. Dynamic+ Injunction:
   • Allows the plaintiff to notify the Court-appointed nodal officers or ISPs of new infringing URLs/domains as they emerge.
   • Enables immediate blocking of such rogue websites without filing fresh suits or seeking new orders.
3. Blocking Orders:
   • Directed Domain Name Registrars (DNRs) to suspend access to infringing domains within 72 hours.
   • Mandated the Department of Telecommunications (DoT) and the Ministry of Electronics and Information Technology (MeitY) to ensure compliance by Internet Service Providers (ISPs).

Evolution of Injunctive Relief in Combatting Digital Piracy

Indian courts have progressively adapted their legal remedies to address the dynamic nature of online piracy. Initially, the Delhi High Court introduced dynamic injunctions. Building upon this, the Dynamic+ injunction was introduced to protect not only existing copyrighted works but also future works as soon as they are created. Most recently, the Delhi High Court has granted superlative injunctions, an advanced iteration of the Dynamic+ injunction. These orders are designed for real-time enforcement, allowing rights holders to directly notify authorities about new infringing websites or applications, facilitating immediate action. InStar India Pvt. Ltd. v. IPTV Smarter Pro & Ors.², the Court issued such an injunction to prevent unauthorized streaming of ICC T20 World Cup 2024 content. These developments reflect the Indian Judiciary's commitment to evolving legal frameworks that effectively combat the sophisticated and rapidly changing landscape of digital piracy.

Notable recent cases:

1. Star India Pvt. Ltd. v. Magicwin.Games & Ors.³(May 2024)
   The Hon'ble Delhi High Court issued a Dynamic+ injunction to protect Star India's exclusive broadcast rights for the ICC Men's T20 World Cup 2024. The order restrained rogue betting websites from unauthorized streaming and mandated real-time blocking of new infringing domains identified by the plaintiff.
2. DAZN Limited v. Buffsports.Me & Ors.⁴(June 2025)
   The Hon'ble Delhi High Court granted a Dynamic+ injunction to safeguard DAZN's exclusive media rights for the FIFA Club World Cup 2025. The court directed immediate blocking of identified rogue websites and authorized real-time blocking of new infringing domains upon notification by the plaintiff.
3. Warner Bros. Entertainment Inc. & Ors. v. Moviesmod.Bet & Ors.⁵(October 2024)
   The Hon'ble Delhi High Court issued a Dynamic+ injunction to protect copyrighted content of multiple studios, including Warner Bros., Disney, and Netflix. The order restrained 45 rogue websites from disseminating existing and future content and allowed the plaintiffs to notify authorities about new infringing sites for immediate action.

Conclusion

The Hon'ble Delhi High Court's decision inJioStar India v. criclk.com & Ors., underscores the Judiciary's responsiveness to the challenges posed by 21st-century piracy. By granting a Dynamic+ injunction, the Court has not only protected the commercial interests and exclusive rights of the plaintiff but also signaled to infringers that the arm of the law can and will adapt to meet the demands of the digital age.

Footnotes

1 Jiostar India Pvt. Ltd. v. criclk.com & Ors. (CS(COMM) 566/2025)

2 Star India Pvt. Ltd. v. IPTV Smarter Pro & Ors., CS(COMM) 108/2025.

3 Star India Private Limited v. Magicwin.Games, 2024 SCC OnLine Del 4386

4 DAZN Limited v. Buffsports.Me & Ors , CS (COMM) 412/2025

5 Warner Bros. Entertainment Inc. & Ors. Vs. Moviesmod.Bet & Ors., Delhi High Court, CS(COMM) 738/2024

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