Delhi High Court Issues 'Dynamic+' Injunction to Block Illegal Serie A Streaming

New Delhi – In a significant move to protect the broadcast rights of live sporting events, the Delhi High Court has granted a 'Dynamic+' injunction in favour of global sports entertainment platform DAZN Limited, restraining 26 "rogue" websites from illegally streaming matches of the ongoing 'Serie A Championship'. The order, passed by Justice Tejas Karia on November 6, 2025, underscores the judiciary's evolving approach to combating online piracy through robust and adaptable legal remedies.

The interim order in DAZN Limited & Anr. v. 9GOALS.IO & Ors. [CS (COMM) 1152/2025] not only blocks the currently identified infringing websites but also establishes a mechanism for the real-time blocking of any new platforms that emerge to pirate the live football matches. This decision reinforces the Delhi High Court's position as a leading jurisdiction for intellectual property enforcement and offers a powerful tool for rights holders battling the persistent and fluid nature of digital piracy.

Background of the Dispute

DAZN Limited, the plaintiff, approached the High Court seeking urgent protection for its exclusive global media rights for the Serie A Championship, which it holds under a comprehensive licensing agreement. The company presented evidence demonstrating that numerous websites were illegally and concurrently streaming live match broadcasts, making DAZN's copyrighted content available to the public for free and without authorization.

The plaintiff, represented by Mr. Siddharth Chopra, argued that these rogue websites were actively reproducing and communicating their broadcast content, leading to significant financial losses and a dilution of the value of their exclusive rights. They contended that without an immediate and expansive injunction, the very purpose of acquiring expensive broadcast rights would be defeated, causing irreparable harm to their business model, which relies on subscription revenue.

The Court's Prima Facie Findings

After examining the evidence, Justice Karia determined that DAZN had successfully established a prima facie case for interim protection. The Court acknowledged the substantial financial investment required to secure exclusive media rights for premier sporting events and recognized the severe economic damage caused by unauthorized dissemination.

The Court observed that the unauthorized streaming of live sports broadcasts could inflict irreparable harm on DAZN's revenue streams. More critically, it noted the recurring and pervasive nature of the threat posed by such infringing platforms.

“The issue of rogue websites engaging in the piracy of copyrighted content presents a recurring threat and disseminating or communicating any portions of the Event, without proper authorization or licensing from the Plaintiffs, would violate the Plaintiffs' Exclusive Rights,” the Court stated.

This observation framed the dispute not as a one-time infringement but as a continuous and technologically enabled challenge that requires an equally sophisticated legal response. The balance of convenience, the Court found, clearly tilted in favour of the plaintiff, as a failure to grant an injunction would lead to unquantifiable losses, whereas the defendants (the rogue websites) had no legitimate right to broadcast the content.

Invoking the 'Dynamic+' Injunction: A Potent Remedy

The cornerstone of the Court's order is its reliance on the 'Dynamic+' injunction, a legal instrument refined by the Delhi High Court to provide a more effective remedy against online piracy than the traditional static injunction.

The Court explicitly referred to its earlier landmark ruling in Universal City Studios LLC v. Dotmovies.baby . In that case, the court had developed the concept of a "Dynamic+" injunction to protect copyrighted works, including future broadcasts, from being uploaded on rogue websites. This type of injunction empowers the plaintiff to combat "hydra-headed" infringing sites that frequently change their domain names (e.g., from '9goals.io' to '9goals.net' or '9goals.tv') or use different IP addresses to evade blocking orders.

Following the same judicial reasoning, the Court in the DAZN case found a similar approach was warranted. It concluded that a standard injunction against only the 26 identified websites would be insufficient, as infringers could easily circumvent the order by creating new domains or mirror websites. The 'Dynamic+' remedy addresses this by creating a framework for ongoing enforcement without requiring the plaintiff to return to court for a new order for every new infringing URL.

Operative Directions and Mechanism for Enforcement

The Court's order laid out a clear, multi-step process for enforcement:

1. Immediate Restraint: The 26 identified websites were immediately restrained from hosting, streaming, rebroadcasting, or otherwise communicating any part of the Serie A Championship without authorization from DAZN.
   
   
2. Real-Time Blocking: The Court directed that if DAZN discovers any new websites illegally streaming the championship, it can immediately communicate the details of these new infringing URLs to the concerned Domain Name Registrars (DNRs) and Internet Service Providers (ISPs). The DNRs and ISPs are then mandated to block access to these sites in real-time.
   
   
3. Judicial Oversight: To maintain judicial oversight and prevent misuse, DAZN was directed to periodically file affidavits with the Court, listing the newly identified infringing websites. Upon filing, the injunction automatically extends to these new entities, ensuring the Court remains informed of the order's expanding scope.

This mechanism provides the agility needed to counter piracy during live events, where infringements occur in real-time and any delay in enforcement renders the remedy ineffective.

Legal Implications and Significance

This order holds several key implications for intellectual property law and the broadcasting industry:

• Strengthening Protection for Live Broadcasts: The decision solidifies the legal protection available for rights holders of live events, particularly sports, which are highly susceptible to real-time piracy. It recognizes that the value of such content is time-sensitive and requires immediate and proactive enforcement.
• Affirmation of Section 37 Rights: By granting the injunction, the Court implicitly affirms the broadcaster's rights under Section 37 of the Copyright Act, 1957. This section grants a special "broadcast reproduction right" to broadcasting organizations, which is distinct from the copyright in the underlying work. The order protects the broadcast signal itself from unauthorized re-communication.
• The 'Dynamic+' Injunction as a Standard Tool: The Court's reliance on the Universal City Studios precedent signals that the 'Dynamic+' injunction is becoming a standard tool in the arsenal of Indian courts against online piracy. This provides predictability for rights holders and puts potential infringers on notice that their attempts to evade injunctions through technical manoeuvres will likely fail.
• Shifting the Onus: The order effectively shifts a part of the enforcement onus onto the intermediaries (ISPs and DNRs) by mandating their cooperation in the real-time blocking process. This collaborative approach is seen as essential for effectively policing the vast expanse of the internet.

For legal practitioners, this case serves as a clear blueprint for framing suits involving digital piracy of live content. It highlights the importance of providing comprehensive evidence of infringement and specifically praying for a dynamic and future-facing injunction that can adapt to the defendant's evasive tactics.

The matter has been scheduled for its next hearing on February 27, 2026, where the Court will likely review the implementation of its order and the affidavits filed by DAZN.