The Delhi High Court has granted a Dynamic+ injunction in a landmark ruling, empowering copyright holders to combat online piracy by notifying ISPs and Domain Name Registrars (DNRs) to block mirror, alphanumeric, or redirect websites that facilitate infringement. This decision reinforces the judiciary's stance against rogue websites while balancing the need for judicial oversight.
Background & Facts
The Dispute
The plaintiffs, Home Box Office Inc & Ors., filed a commercial suit (CS(COMM) 740/2026) against Streamzy.to & Ors., alleging large-scale copyright infringement. The defendants, categorized into four groups
Case Details
Home Box Office Inc & Ors. v. Streamzy.to & Ors.
2026:DHC:5967
Court
High Court of Delhi
Date
27 July 2026
Case Number
CS(COMM) 740/2026
Bench
Hon’ble Mr. Justice Anup Jairam Bhambhani
Counsel
Pet: Mr. Saikrishna Rajagopal, Ms. Suhasini Raina, Mr. Raghav Goyal, Mr. Aditya Sing Thakur, Mr. Affan Moin
Res: Ms. Kruttika Vijay, Ms. Harshitha Rathod, Ms. Suvarna Singh, Ms. Shweta Sahu, Ms. Deeksha Pokhriyal, Ms. Manisha Agrawal Narain, Mr. Nipun Jain
Frequently Asked Questions
A Dynamic+ injunction is a court order that allows copyright holders to notify ISPs and Domain Name Registrars (DNRs) to block newly discovered mirror, alphanumeric, or redirect websites that facilitate infringement, without requiring fresh judicial orders for each instance. The court retains oversight by requiring plaintiffs to file impleadment applications for judicial confirmation.
Courts consider factors such as: (a) whether the primary purpose of the website is to commit or facilitate copyright infringement; (b) the flagrancy of the infringement; (c) masked registrant details; (d) silence after takedown notices; (e) directories or indexes of infringing content; (f) disregard for copyright laws; (g) prior court orders blocking the website; (h) guides to circumvent blocking orders; (i) volume of traffic; and (j) any other relevant matter, as laid down in UTV Software Communication Ltd. v. 1337X.To & Ors.
No. While plaintiffs can notify ISPs/DNRs of infringing websites, ISPs/DNRs must technically verify if the website is a mirror/alphanumeric/redirect of an injuncted site. Blocking is a pro-tem measure, and judicial confirmation through impleadment applications is mandatory. ISPs/DNRs retain safe harbour protection under Section 79 of the IT Act, 2000, as they are not adjudicating but merely verifying.
If a plaintiff’s assertion about a website being a rogue site is found to be baseless, false, or not bona fide, the court may impose strictures or directions against the plaintiff. This ensures accountability and prevents abuse of the Dynamic+ injunction mechanism.
