Delhi High Court permanently restrains RSY News from using ANI videos after finding unauthorised copying of 12 uploads

ANI Media Pvt. Ltd. sued RSY News and Google LLC, alleging that RSY News had uploaded twelve videos across four YouTube channels reproducing, wholly or substantially, ten ANI videos without permission.

ANI sought injunctions, removal of the videos, public acknowledgment and ₹2,00,00,500 in damages.

The Court had granted interim injunctive relief; RSY News was served but did not appear or file a written statement and was proceeded against ex parte.

Google, the YouTube platform operator, appeared and stated that the identified URLs had been removed by the uploader and that it would comply with an appropriate court direction.

ANI later gave up its request to have RSY News’s YouTube channels deleted and applied for summary judgment.

1. Whether ANI had established copyright ownership in the original videos and unauthorised reproduction and communication of those works by RSY News

2. Whether RSY News had no real prospect of successfully defending the copyright claim, such that the suit could be disposed of by summary judgment without trial

3. Whether the requested injunctive, removal, public-acknowledgment and damages reliefs should be granted, including directions against Google

Order XIII-A Rule 3 of the Code of Civil Procedure, 1908 permits summary judgment where a party has no real prospect of succeeding or defending and there is no compelling reason for trial; Rule 27 of the Delhi High Court Intellectual Property Rights Division Rules, 2022 enables summary judgment in IPD matters on analogous principles.

Reliance Eminent Trading and Commercial Private Limited v. Delhi Development Authority, 2026 INSC 436, explains that a real prospect must be substantial rather than fanciful, and that the court must consider the record and reasonably foreseeable trial evidence without conducting a mini-trial.

Under Sections 2(f), 17(b), 14(d) and 51(a)(i) of the Copyright Act, 1957, a qualifying cinematograph film is a protected work; the person at whose instance it is made for valuable consideration is, absent an agreement to the contrary, its first owner; and unauthorised copying or communication to the public infringes the owner’s exclusive rights.

Section 52(1)(a)(iii) provides an exception for fair dealing for reporting current events, but the use must qualify as fair dealing.

The Court also referred to Order VIII Rules 1 and 10 CPC concerning the time limit for filing a written statement and the court’s power to pronounce judgment when a required written statement is not filed.

The plaintiff’s unrebutted pleadings, the professional services agreement and the video comparisons established that ANI owned copyright in the recordings and that RSY News had reproduced and communicated them to the public.

Most of the impugned videos reproduced the originals in their entirety or virtually so; the remaining pleaded uses included substantial segments.

RSY News’s asserted licence from Swami Entertainment was unsupported by evidence despite being within its knowledge, and the Court treated that defence as fanciful.

The Court also rejected fair dealing: wholesale copying substituted for ANI’s works, while the specific uses of the subscriber-only footage and the exclusive interview were neither trivial nor incidental to independent reporting.

The relevant matters were documentary and admitted or unrebutted, so no credibility assessment or oral evidence was required; RSY News had no real prospect of defending the claim and no compelling reason justified a trial.

The Court confined relief against Google to the specifically identified infringing URLs, declined public acknowledgment as unnecessary, and declined damages.

RSY News was permanently restrained from exploiting ANI’s original videos or other copyrighted works without authorisation and directed to remove the twelve identified videos and other infringing content, to the extent not already removed.

The earlier directions against Google to take down, block and disable access to the identified videos were confirmed.

The claims for public acknowledgment and damages were declined; the request to delete RSY News’s channels had been given up.

The interim-injunction application was disposed of as merged with the decree, and the suit and pending applications were disposed of accordingly.