Star India Pvt. Ltd. v. Piyush Agarwal

Delhi High Court – Dynamic Injunction in Copyright Infringement

“Digital piracy cannot hide behind changing identities.”

SHORT DESCRIPTION

Star India Pvt. Ltd. v. Piyush Agarwal is a significant Indian copyright enforcement case dealing with online piracy and illegal streaming of copyrighted television content. The Delhi High Court addressed the growing challenge of rogue websites that repeatedly infringe copyright by changing domain names and technical identifiers. This case strengthened judicial tools by recognising and applying the concept of a dynamic injunction to effectively curb online piracy.

FACTS OF THE CASE

Star India Pvt. Ltd. is a leading broadcaster and content owner in India, holding exclusive copyrights over a wide range of television programmes, sports broadcasts, and entertainment content. The company discovered that several rogue websites were illegally streaming and distributing its copyrighted content without authorisation, causing substantial commercial loss and dilution of exclusive rights.

Piyush Agarwal and other unidentified defendants were alleged to be operating or facilitating these rogue websites. Despite previous blocking orders, the infringing platforms continued to resurface under new domain names, mirror websites, and altered URLs, making traditional injunctions ineffective.

Star India approached the Delhi High Court seeking stronger remedies to prevent continuous and habitual infringement of its copyrighted works in the digital environment.

ISSUES INVOLVED

The primary legal issue before the Court was whether conventional injunctions were sufficient to deal with online piracy where infringing websites frequently change their digital identities. The Court also examined whether it could authorise copyright owners to approach internet service providers directly for blocking newly emerging mirror or redirect websites without returning to court each time.

COURT’S FINDINGS AND OBSERVATIONS

The Delhi High Court recognised that online piracy operates in a highly adaptive and evasive manner. The Court held that rogue websites exist solely for infringing copyrighted content and have no legitimate business purpose. It observed that requiring copyright owners to seek fresh injunctions for every new mirror website would place an unreasonable burden on them and render judicial protection ineffective.

Accordingly, the Court granted a dynamic injunction, allowing Star India to notify internet service providers to block newly discovered mirror or redirect websites that were substantially similar to the original infringing platforms. This approach balanced enforcement efficiency with due process safeguards.

SUGGESTION / PRACTICAL TAKEAWAY

This judgment provides a powerful precedent for copyright owners facing persistent online infringement. It encourages proactive enforcement strategies and recognises the realities of digital piracy. Content creators, broadcasters, and OTT platforms can rely on this decision to protect their intellectual property more effectively in the online space.

JUDGMENT

The Delhi High Court granted a dynamic injunction in favour of Star India Pvt. Ltd., enabling effective blocking of infringing websites and their future variants without repeated litigation.