A Narrower Fix to an Old Problem
On July 27, 2026, the Delhi High Court granted Home Box Office and its co-plaintiffs a dynamic interim injunction against 30 websites, including Streamzy.to, that were streaming HBO content without authorization. The order itself is unremarkable by now — Indian courts have blocked rogue streaming sites for years. What matters is what Justice Anup Jairam Bhambhani refused to do: he declined to let either the plaintiffs or the internet service providers and domain name registrars enforcing the order decide, on their own authority, that a website is "rogue" and therefore blockable (Bar and Bench; Verdictum).
The case, Home Box Office Inc. & Ors. v. Streamzy.to & Ors. (CS(COMM) 740/2026, neutral citation 2026:DHC:5967), is a direct descendant of UTV Software Communications Ltd. v. 1337X.to, the 2019 Delhi High Court ruling that introduced "dynamic injunctions" to Indian copyright law. In that case, Justice Manmohan confronted the same problem regulators and rights holders face everywhere: blocked piracy sites resurface within hours under a slightly different domain, an IP address, or an alphanumeric alias, rendering a static blocking order useless almost as soon as it is issued (IndianKanoon, UTV v. 1337X.to).
Steelmanning the Rightsholders
The frustration behind these suits is legitimate. India's media and entertainment sector lost an estimated ₹224 billion (~$2.7 billion) to piracy in 2023, with streaming platforms alone accounting for roughly ₹87 billion of that figure, according to an EY-IAMAI report published in October 2024 (EY-IAMAI). Forcing a rights holder to re-litigate from scratch every time a blocked site reappears under a new domain is not a serious anti-piracy strategy — it is a war of attrition the pirate wins by default, since spinning up a mirror costs minutes and re-approaching a court costs months. Some form of expedited, lower-friction mechanism for extending an existing injunction to a verified clone is a reasonable, proportionate response to a genuinely adversarial and fast-moving problem.
The Court's Answer: Verify, Block Pro Tem, Adjudicate Later
What the Streamzy.to order does — and what earns it the "Dynamic+" label in reporting — is formalize a middle path. When a plaintiff discovers what it believes is a mirror, redirect, or alphanumeric variant of an already-injuncted site, it must furnish an affidavit with supporting evidence to the relevant ISP or domain name registrar. That intermediary then performs a technical verification — essentially confirming the new domain resolves to the same infringing service — and may block it on a pro-tem basis. Critically, the plaintiff must simultaneously file an application before the court to formally implead the new site, meaning the block is provisional until a judge signs off (Verdictum; Delhi High Court order, 2026:DHC:5967).
The court's own framing draws the line precisely: an intermediary can confirm that Domain B is technically the same service as already-blocked Domain A. It cannot decide, in the first instance, whether a website qualifies as rogue in the legal sense — that determination "must continue to rest with the court," not with "the unilateral assessment of the plaintiffs" or "the sole satisfaction of an intermediary," as the judgment puts it.
Why the Guardrail Is the Real Story
This distinction is the part worth defending editorially, and it cuts against the instinct to see any pro-rightsholder ruling as a win for enforcement at speech's expense. Around the world, site-blocking regimes have a well-documented failure mode: once ISPs or registrars are handed discretion to decide what counts as infringing, blocking creeps outward into overbroad, opaque takedowns of legitimate services that happen to share infrastructure, IP ranges, or naming conventions with a pirate site. The EU's experience with overbroad blocking injunctions and the well-known problem of blocklist creep is precisely why courts, not private intermediaries, should retain adjudicatory authority — and this is exactly what Justice Bhambhani's order preserves.
By keeping ISPs and DNRs in a purely technical role — matching domains, not judging infringement — the order avoids deputizing telecom and hosting companies as copyright police, a role they are neither qualified for nor accountable in. That matters more in India than in most jurisdictions, given how broadly Section 69A of the IT Act and the 2021 IT Rules already empower government-directed blocking outside the judicial process. A court insisting that it alone gets the final word, even while streamlining enforcement, is a check worth preserving as India's site-blocking jurisprudence matures.
Where the Risk Still Sits
The soft spot is the word "pro-tem." A provisional block that takes effect the moment an ISP nods along to a plaintiff's affidavit is still a block — traffic is redirected or refused before any judge has looked at the new domain. If impleadment applications are not filed and heard promptly, "provisional" can quietly become permanent in practice, and legitimate mirror sites — a startup accidentally sharing infrastructure, an archival project, a VPN reseller — could be swept in by an overzealous verification. The framework's soundness ultimately depends on Delhi High Court's registry moving fast enough on impleadment applications that pro-tem blocking doesn't outlive its own justification. That is an implementation question, not a design flaw — and one worth watching as the first mirror-site verifications under this order are filed.