By the time a court blocks an unauthorised live stream, the match may already be over and the commercial value of the exclusive broadcast right exhausted. In online copyright enforcement, speed is not merely a procedural advantage. It determines whether the remedy preserves the right at all. The Delhi High Court recognised this urgency while protecting ongoing cricket broadcasts, observing that delayed blocking would cause irreparable infringement, revenue loss and injury to the exclusive rights holder.
The problem is not limited to identifying the first infringing website. Rogue operators can shift the same stream to a mirror domain, redirect users to another address or return through a minor alphanumeric variation. A conventional injunction may restrain the website named in the suit, while the underlying operation continues through a new digital entrance.
Three Delhi High Court orders delivered in July 2026 trace the judicial response to this moving target. In Sony Pictures Networks India Private Limited v. Cricfree.cyou1, the Court granted urgent protection for ongoing and future sporting events and permitted later-discovered infringing websites to be blocked during the currency of those events. Nineteen days later, Sony Pictures Networks India Private Limited v. Cricgo.pro2 applied a similar mechanism shortly before the Commonwealth Games 2026 commenced. A week thereafter, Home Box Office Inc. v. Streamzy.to3 accepted the need for rapid enforcement, but examined more closely who should decide whether an unidentified website is genuinely a mirror of an already restrained rogue operation.
Read together, the orders move the law beyond the question of whether an injunction can follow a rogue website. They raise the more difficult issue of how quickly it may travel, what evidence must guide it and whether its extension can be triggered by a rights holder without first returning to Court.
Tension Between Real-Time Blocking and Judicial Oversight
The broadcaster’s legal interest begins with Section 37 of the Copyright Act, 1957,which creates a broadcast reproduction right and protects against unauthorised rebroadcasting and communication of a broadcast to the public. Sections 51 and 55 of the Copyright Act, 1957,[4] address infringement and civil remedies. Interim restraint is ordinarily granted under Order XXXIX Rules 1 and 2 of the Code of Civil Procedure, 1908,[5] while Section 151 preserves the Court’s inherent procedural powers.
These provisions assume that the defendant restrained today will remain identifiable tomorrow. Rogue websites defeat that assumption by concealing their operators and changing the technical means through which the same content is accessed.
The Delhi High Court addressed this characteristic in UTV Software Communication Ltd. v. 1337X. to.and ors4 The Court distinguished a lawful platform containing some infringing material from a flagrantly infringing online location whose primary purpose is to facilitate piracy. Relevant indicators include systematic and voluminous infringement, masked registrant information, disregard of takedown notices, indexing of pirated content and measures intended to circumvent blocking orders.
The distinction is essential. The presence of infringing material on a website does not, by itself, justify disabling access to the entire platform. Site-wide relief becomes proportionate where infringement is not incidental but forms the organising purpose of the website.
UTV Software also introduced the dynamic injunction. Once a website had been judicially identified as rogue, mirror, redirect and alphanumeric versions providing access to the same operation could be brought within the injunction through an application for impleadment under Order I Rule 10 of the Code of Civil Procedure, 1908,[5] supported by evidence.
The remedy later developed into the Dynamic+ injunction in Universal City Studios LLC v. Dotmovies Baby5 That decision recognised that protection confined to works already produced may fail where a new film, series or broadcast is uploaded immediately upon release. Dynamic+ relief therefore permits the injunction, in an appropriate case, to protect future works once copyright arises, subject to sufficient evidence and undisputed ownership.
The Sony orders applied this jurisprudence to live sport, where the effective life of the remedy is especially short.
In Cricfree, Sony sought protection for cricket tours and other sporting events over which it held exclusive media rights. The Court restrained eight identified websites, directed domain name registrars to suspend their domains and required internet service providers to block access. More significantly, during the currency of the sporting events, Sony could notify the relevant intermediaries of additional websites found to be streaming its content. Immediate blocking could follow, while Sony filed affidavits identifying the domains and sought their subsequent impleadment.
Cricgo adopted the same real-time structure for the Commonwealth Games 2026 and Australian Open 2027. The defendant websites were alleged to have systematically streamed protected sporting content, displayed Sony channel logos and concealed their ownership through domain privacy services. The Court permitted Sony to communicate details of newly discovered websites to domain registrars, internet service providers and governmental authorities for immediate blocking, followed by affidavits and impleadment applications.
Both orders recognised the commercial logic of live-event protection. If the rights holder must prepare and argue a fresh injunction application each time the same stream migrates, the event may conclude before the order becomes effective. Yet the solution creates another legal problem. A later-identified domain may be a genuine mirror that simply reproduces an operation already found to be rogue. It may also be an independent platform containing mixed, unrelated or lawful content. If blocking follows solely from the rights holder’s assertion, an injunction passed against named defendants becomes capable of extending to unidentified websites without prior judicial scrutiny. If an internet service provider or domain registrar must determine whether copyright infringement exists, a neutral intermediary is placed in the position of adjudicating legality.
This concern is reinforced by Section 79 of the Information Technology Act, 2000, which grants conditional safe-harbour protection to intermediaries operating neutrally. In Shreya Singhal v. Union of India6. The Supreme Court held that an intermediary’s obligation to remove or disable access cannot ordinarily arise from a private allegation that requires it to independently decide whether content is unlawful. “Actual knowledge” must follow a court order or a valid governmental direction.
Streamzy placed this institutional concern at the centre of dynamic enforcement. The Court accepted that requiring HBO to obtain a completely fresh injunction whenever a rogue website resurfaced would make the plaintiff chase a moving target and permit the original order to be defeated with ease. At the same time, it refused to grant the plaintiff, the domain registrars or the internet service providers unrestricted authority to determine that every later-notified website was liable to be blocked. The Court divided the process into legal adjudication and technical verification. HBO could furnish an affidavit and supporting material identifying a website as a mirror, redirect or alphanumeric version of an already restrained domain. The intermediary could then verify whether the new location was technically another means of accessing the same defendant website. If technical continuity was established, the existing injunction could be enforced against it as a pro tem measure. HBO was simultaneously required to apply for impleadment, leaving the Court to determine whether blocking should continue.
The intermediary was not authorised to decide whether a new and independent website infringed copyright. Its role was confined to identifying technological continuity with a wrong already placed before the Court. An intermediary could approach the Court if it considered blocking inappropriate, while false, baseless or mala fide assertions by the plaintiff could invite adverse orders.
The distinction offers a principled answer to the speed problem. An injunction may travel immediately where the new domain is technically continuous with a rogue operation already adjudicated. Where the identity of the operation or the character of the alleged infringement is genuinely new, judicial scrutiny must travel with it.
The mechanism nevertheless leaves practical questions open. The orders do not prescribe a uniform technical standard for establishing a mirror website. Similar branding, source content, interfaces, registrant information, hosting infrastructure or streaming links may indicate continuity, but none is necessarily conclusive by itself. A false positive may disable access to lawful material before the Court reviews the matter. Post-blocking correction must therefore operate quickly enough to matter, particularly where a website’s traffic and commercial value may be affected immediately.
Dynamic+ relief presents a related difficulty. It protects works that may not exist when the original order is passed. Its legitimacy therefore depends upon clearly defined future rights, reliable evidence of ownership and a careful distinction between the already identified rogue operation and an independent website not previously examined.
Conclusion
A static injunction cannot protect a live broadcast from an operator capable of changing domains during the match. Dynamic and Dynamic+ injunctions respond by allowing the order to follow mirror websites, redirect pages, alphanumeric variants and, in suitable cases, future works.
The July 2026 orders suggest an emerging layered model. The Court first identifies the principal websites as rogue. The rights holder then supplies evidence of a newly discovered location. The intermediary verifies whether that location is technically continuous with the restrained operation and implements the order temporarily. The Court retains authority over impleadment, continuation and correction.
This structure recognises that effective copyright protection requires enforcement at the speed of the infringement. It also preserves the boundary between technical execution and legal determination.
The rights holder may identify the moving target. The intermediary may verify that it is the same target. The decision that an online location should remain blocked must ultimately remain judicial.
Citations
Expositor(s): Adv. Aparna Shukla
