Dynamic+ Injunction Against Rogue Websites: Balancing Copyright Protection with Intermediary Neutrality

1. Case Snapshot

• Case Name: Home Box Office Inc & Ors. vs Streamzy.To & Ors.

• Citation: 2026:DHC:5967

• High Court: High Court of Delhi

• Bench: Hon'ble Mr. Justice Anup Jairam Bhambhani

• Date of Judgment: July 27, 2026

• Area of Law: Intellectual Property – Copyright Infringement; Internet Intermediaries; Dynamic Injunctions; Cyberspace

2. Judgment in Brief

The Delhi High Court granted an ad-interim injunction against 30 "rogue websites" engaged in unauthorized streaming of the plaintiffs' copyrighted content. The Court also issued directions for blocking mirror/redirect/alphanumeric websites that may emerge to circumvent the injunction. The Court adopted a balanced approach: ISPs/DNRs were directed to technically verify and block mirror websites upon the plaintiffs' affidavit, with the plaintiffs required to simultaneously file an application before the Court for formal impleadment. This ensured that judicial scrutiny remained intact while addressing the "hydra-headed" nature of online piracy. The Court also clarified that intermediaries retain safe harbour protection and can approach the Court if they have concerns about blocking any website.

3. Relevant Facts

• The plaintiffs (HBO Inc. and others) own copyright in various cinematographic films and shows.

• Defendants Nos. 1-30 are "rogue websites" that host/stream the plaintiffs' content without license, sometimes immediately upon release or even before release.

• The registrant details of these websites are masked, making it impossible to identify the actual operators.

• Def

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