The hydra problem
Online piracy has a structural feature that ordinary injunctions struggle with: when one infringing website is blocked, mirror sites, redirect links and slightly altered domain names appear almost immediately, hosting the same content. Requiring a rights holder to file fresh proceedings for each new address would make enforcement a game of whac-a-mole that the infringer always wins. The dynamic injunction was the Indian judiciary’s answer to that problem.
In UTV Software Communications Ltd. v. 1337X.to & Ors. (2019), the Delhi High Court — drawing on a Singapore precedent — held that where a website is established as a “flagrantly infringing online location,” a single order can be extended to its mirror, redirect and alphanumeric variants without the rights holder returning to court for a fresh adjudication each time. The Court set out non-exhaustive factors for identifying such rogue websites (masked registrant details, absence of traceable contact information, content overwhelmingly comprising unlicensed works, and the like) and created a mechanism by which a rights holder could apply to the Joint Registrar, on affidavit, to extend an existing injunction to newly discovered variants, with directions to internet service providers and the relevant authorities to implement blocking.
The insight of the dynamic injunction is procedural: static orders cannot contain continuously evasive infringement, so the order itself must be able to move.
From websites to live sport and to future works
Two lines of expansion followed. First, the tool moved beyond film catalogues to live events, where the value of content is almost entirely in the moment of broadcast. Courts have granted anticipatory relief ahead of major tournaments, and in the context of premier cricket events have directed real-time blocking of rogue streams, recognising that waiting for conventional timelines would render broadcasting rights worthless. Second, in Universal City Studios v. Dotmovies.baby (2023), the Court developed the “dynamic+” injunction to protect works not yet released, so that a rights holder is not left exposed in the window before a title even reaches the market. The principle has also been extended beyond copyright to trademark misuse through fraudulent websites.
The 2026 calibration: verification, not adjudication
Aggressive as the remedy is, the courts have been alert to its risks, and a 2026 decision drew an important line. In Home Box Office Inc. v. Streamzy.to, the Delhi High Court granted a dynamic injunction against a set of rogue websites but held that the final determination of whether a newly discovered site is genuinely infringing must rest with the court — not be delegated to internet service providers, domain registrars or the plaintiffs acting on their own. Intermediaries can technically verify that a site is a mirror of a blocked one; they cannot be handed the adjudicatory power to decide “rogue” status. Blocking of new sites remains a provisional measure subject to continued judicial oversight.
That calibration matters. It preserves the effectiveness of the dynamic injunction while keeping the ultimate judgment about infringement where it belongs with the court. For rights holders in film, broadcasting, over-the-top streaming and live sport, the practical significance is that Indian courts have built a genuinely responsive enforcement tool, but one that is being refined with attention to due process and the position of the intermediaries asked to give it effect.
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