Bhootam Bhayam released in theatres on 24 July 2026, and on that very same day the Madras High Court passed an order meant to keep it off pirate websites and illegal cable feeds before the damage could spread. In Zee Entertainment Enterprises Limited v. Bharath Sanchar Nigam Limited & Ors., Justice K. Kumaresh Babu granted Zee Entertainment an ad interim injunction against twenty nine internet service providers and four cable television operators, restraining them from carrying infringing copies of the film and directing that newly discovered infringing websites be blocked once Zee identifies and notifies them. The order runs to barely a page of substantive reasoning, yet it captures, almost in miniature, how Indian courts have learned to move at the speed piracy now demands.
Two Applications Filed Together
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Zee filed two connected applications within the same commercial suit, OA No. 718 of 2026 against the internet service providers and OA No. 719 of 2026 against the cable operators. The internet service provider application named twenty nine respondents including large national carriers such as BSNL, MTNL, Bharti Airtel, Vodafone, and Reliance Jio, alongside several regional broadband and cable internet operators. Zee asked the court to restrain each of them from hosting, transmitting, or otherwise making available the film through any website or webpage, and crucially, to extend that restraint to any future website Zee identifies and reports in writing after the film’s release, without requiring a fresh application every time a new pirate site appears.
The cable television application targeted four operators active largely around Chennai. Here Zee sought a wider restraint covering copying, recording, camcording, reproduction, and distribution of the film through an extensive list of formats, running from CDs and DVDs to DTH services, conditional access systems, and satellite transmission. Between the two applications, the order effectively covers every commercially significant channel through which a pirated print of a freshly released film tends to travel in India, from the open internet down to the local cable feed.
Why Courts Intervene Before Infringement Happens
An injunction granted before any actual infringement has occurred is not the ordinary course of copyright litigation, and courts do not hand it out lightly. What justifies it here, as in similar applications before other High Courts over the past decade, is the recognised commercial reality of how a film’s earning life is structured. A film earns the overwhelming share of its revenue in the days immediately following release, through theatrical collections and licensed streaming or television deals that depend on scarcity and exclusivity. Pirated prints that surface within hours of release do not merely cause future loss, they collapse the very window in which the film was ever going to make its money, and no damages award calculated months later can restore that lost window.
This is why applications of this kind proceed on an apprehended or quia timet basis, seeking protection against a threatened wrong rather than waiting for the wrong to actually occur. Indian courts, beginning with early cable piracy cases in Delhi and expanding through a long line of Madras High Court orders for Tamil, Telugu, and now Marathi language films, have treated this apprehension as sufficiently concrete once the plaintiff shows genuine ownership and an imminent, confirmed release date, rather than a speculative fear of future harm.
Indian courts have long applied a three part test before granting any interim injunction, asking whether the plaintiff shows a prima facie case, whether the balance of convenience favours interim protection, and whether the plaintiff would suffer irreparable injury without it. Zee’s application satisfied all three with relatively little friction. The CBFC certificate supplied the prima facie case on ownership, the four week limit together with the indemnity condition kept the balance of convenience from tilting unfairly against the respondents, and the well established commercial reality of piracy spreading within hours of release supplied the irreparable injury. Courts rarely spell out this three part structure explicitly in short interim orders of this kind, but the reasoning underneath fits the template closely enough that a reader familiar with interim injunction jurisprudence can trace each element without difficulty.
The Evidence That Satisfied The Court
Zee supported its case with two documents, the CBFC certificate identifying it as the producer of the film and promotional material confirming the scheduled release date. The court found this sufficient to establish a prima facie case of ownership and imminent commercial exploitation without demanding more elaborate proof at this preliminary stage. This approach is consistent with how Indian courts have handled pre release anti piracy applications for well over a decade now, treating the CBFC certificate as reliable documentary evidence of authorship and release timing precisely because it comes from a statutory body rather than resting on the plaintiff’s own assertion alone.
The court then reasoned that once a film reaches the point of theatrical release, any delay in blocking pirated versions causes harm that money cannot later repair, since the commercial life of a film sits concentrated in its opening days and weeks. Piracy that spreads during that window cannot be undone by a later injunction, however strongly worded that injunction might read. This reasoning explains why courts routinely grant such applications on an ad interim basis rather than waiting to hear from twenty nine internet service providers and four cable operators first, a process that would itself consume the very window the injunction exists to protect.
Balancing Blocking Power Against Legitimate Business Interests
What distinguishes this order from a rubber stamp is the condition the court attached to it. Justice Kumaresh Babu recognised that a blocking direction covering websites, webpages, and future infringing sites identified only after the fact carries a real risk of catching legitimate content or disrupting the ordinary business of an internet service provider along the way. Rather than refuse the relief or narrow it defensively at this early stage, the court required Zee to indemnify the respondents against exactly that risk before the injunction would take effect.
This indemnity requirement reflects a broader and welcome trend in Indian anti piracy practice. Earlier generations of blocking orders sometimes swept in entire websites on the strength of a handful of infringing pages, drawing criticism that innocent content and ordinary internet users bore the cost of protecting a single film. Requiring the plaintiff to accept financial responsibility if the order overreaches shifts some of that risk back onto the party best placed to draft a precise and proportionate blocking request in the first place, without denying the plaintiff the speed it genuinely needs to protect a newly released film.
The Element That Makes This Order Dynamic
The most operationally significant part of the order is easy to miss on a first read. Zee did not simply ask the court to block a fixed list of websites known at the time of filing. It asked for, and received, a mechanism through which any website discovered after the film’s release, including mirror sites or clones of previously blocked domains, can be added to the blocking direction once Zee notifies the internet service providers in writing, without needing to return to court for a fresh order each time a new pirate site surfaces.
This approach traces back to a line of website blocking cases that Indian courts, beginning with the Delhi High Court, developed over the past decade to deal with the reality that pirate websites reappear within hours under a new domain name once the old one is blocked. What began as an innovation aimed at chronic repeat offender websites has since become standard practice for pre release film protection across High Courts, including Madras, precisely because a static blocking list becomes useless the moment pirates register a new address. The order in this case, brief as it is, sits comfortably within that now settled practice rather than breaking new ground.
Procedural Safeguards Behind The Urgency
Speed does not mean the order dispenses with process altogether. The court limited the injunction to four weeks and made it returnable within that period, ensuring the respondents get a genuine opportunity to be heard rather than facing an open ended restraint imposed without their participation. It also permitted private notice through Speed Post with acknowledgment due, a practical concession given that formally serving thirty three separate respondents through ordinary channels before the film’s release would have been impossible within the available time. Compliance with Order XXXIX Rule 3 of the Code of Civil Procedure, which requires prompt notice to the opposite side wherever an ex parte injunction is granted, keeps the process tethered to established civil procedure even while the court moves quickly.
Also Read: Zee Entertainment v. BSNL: Madras High Court Permits Withdrawal of Copyright Suit
Conclusion
This order is a clean example of Indian courts applying a framework that has matured considerably since the early days of film blocking litigation. Granting relief before infringement actually occurs, on the strength of a CBFC certificate and promotional material alone, might have seemed aggressive a decade ago, but it now reflects a realistic response to how quickly pirated content spreads once a film reaches theatres. The four week limit, the indemnity condition, and the requirement of prompt notice together show a court alert to the risk of overreach even while acting under genuine time pressure. If there is a caution worth sounding, it is that the dynamic blocking mechanism, useful as it is, depends heavily on Zee identifying infringing websites accurately and in good faith, since the internet service providers have little practical ability to second guess each notification once the order is in place. On balance though, this is a well calibrated order, and it should give both content owners and internet intermediaries a reasonably predictable template for how these applications will be handled going forward.
Case Title: Zee Entertainment Enterprises Limited v. Bharath Sanchar Nigam Limited & Ors.
