Zee Entertainment Enterprises Ltd v. Mohalla Tech Pvt Ltd (2025 DHC 11002): Territorial Jurisdiction in Online Copyright Infringement Independent of Contractual Exclusive Forum Clauses

1. Introduction

This commentary examines the Delhi High Court’s decision in Zee Entertainment Enterprises Limited v. Mohalla Tech Private Limited, CS(COMM) 745/2023, judgment dated 8 December 2025, delivered by Justice Mini Pushkarna. The judgment decides an application under Order VII Rule 10 CPC seeking return of the plaint for lack of territorial jurisdiction.

The dispute arises from alleged copyright infringement on Mohalla Tech’s popular social media platforms ShareChat and Moj. Zee alleges that, after expiry of its licensing arrangements, Mohalla Tech’s in‑built music libraries continued to make Zee’s repertoire available to users nationwide, including in Delhi, thereby infringing Zee’s copyrights under the Copyright Act, 1957.

Mohalla Tech resisted the suit in Delhi on two principal grounds:

• Contractual exclusive jurisdiction clauses in earlier agreements (User Content and Revenue Sharing Agreement of 10 February 2023 and Licence Agreement of 8 September 2020, with addenda) vested jurisdiction “exclusively” in Mumbai courts.
• Even apart from the contracts, Delhi had no territorial jurisdiction under Section 20 CPC, because mere accessibility of an online platform in Delhi was inadequate; the plaintiff had not shown “targeting” or specific transactions in Delhi.

The judgment is significant for three reasons:

1. It draws a clear doctrinal line between contractual disputes and statutory IP infringement claims, holding that exclusive jurisdiction clauses in expired contracts do not automatically govern subsequent, independent copyright infringement suits.
2. It affirms that in online copyright infringement cases, website/platform accessibility and alleged exploitation in the forum State are sufficient to confer territorial jurisdiction under Section 20(c) CPC, without needing to prove a specific commercial transaction or “targeting” of that State in the sense developed in Banyan Tree.
3. It emphasises that for the purpose of an Order VII Rule 10 objection, the Court must look strictly at the plaint and its documents and proceed on a “demurrer” basis—assuming the plaint allegations are true.

2. Summary of the Judgment

2.1 Nature of the Application

Mohalla Tech filed I.A. 7189/2024 under Order VII Rule 10 read with Section 151 CPC, seeking return of the plaint on the ground that the Delhi High Court lacked territorial jurisdiction. The core planks of the objection were:

• Exclusive jurisdiction clauses in the prior Zee–Mohalla agreements favouring Mumbai.
• Absence of any pleaded cause of action arising in Delhi within the meaning of Section 20(c) CPC.

2.2 Court’s Key Findings

The Court dismissed the application, holding:

1. The suit is not contractual in nature.
   The plaint seeks relief only for statutory copyright infringement (unauthorised exploitation of Zee’s repertoire on ShareChat and Moj after expiry of the licences), not for breach of the UCRS Agreement or the Licence Agreement. There are no pleadings of breach or claims for contractual relief.
2. Exclusive jurisdiction clauses in earlier agreements do not govern this suit.
   Since the present cause of action is independent of the contracts and not “arising out of or in connection with” them, contractual clauses conferring exclusive jurisdiction on Mumbai courts are inapplicable. Termination/expiry of the agreements, coupled with a distinct statutory cause of action, severs the jurisdictional tether to those contracts.
3. Jurisdiction must be tested solely on the plaint (demurrer principle).
   For an Order VII Rule 10 application, the Court is confined to the plaint and documents filed with it, assuming their truth. Defences, including the defendant’s characterisation as an “intermediary” or its reliance on past orders, cannot be used to oust jurisdiction at this stage.
4. Cause of action in copyright suits arises where the infringing content is accessible and exploited.
   The plaint alleges that ShareChat and Moj, via their in‑built music libraries, make Zee’s copyrighted repertoire available to users across India, including Delhi, enabling users to create and share infringing content. These allegations, if accepted, show that part of the cause of action has arisen in Delhi under Section 20(c) CPC.
5. Mere accessibility of the interactive platform plus alleged infringing exploitation is sufficient.
   The Court distinguishes trademark/passing‑off jurisprudence such as Banyan Tree and holds that for copyright infringement, the plaintiff need not prove specific commercial transactions or elaborate “targeting” of Delhi. The alleged unlicensed exploitation of copyrighted works via an interactive platform accessible in Delhi suffices.

On this basis, the Court concluded that a part of the cause of action does arise in Delhi, and the Delhi High Court has territorial jurisdiction. The application for return of plaint was therefore rejected.

3. Factual and Procedural Background

3.1 Parties and Businesses

• Plaintiff: Zee Entertainment Enterprises Limited – a listed media and entertainment company that acquires, produces and exploits a vast repertoire of audiovisual works, sound recordings and underlying musical and literary works (both film and non‑film, Hindi and regional).
• Defendant: Mohalla Tech Private Limited – owner/operator of:
  • ShareChat – a social networking platform; and
  • Moj – a short‑video application, both accessible via sharechat.com and mojapp.in.
  These platforms allow users to create short videos and add music from an in‑built “music library”.

3.2 Prior Commercial Arrangements

The past relationship was organised through two sets of agreements:

1. Licence Agreement (8 September 2020)
   Continued through addenda (12 August 2021; effective 15 July 2022). This licence:
   • Authorised Mohalla Tech to store Zee’s licensed sound recordings on its servers.
   • Permitted making the licensed content available to users.
   • Allowed users to listen, preview, synchronise/incorporate the works into their content.
   • Contained an exclusive jurisdiction clause in favour of Mumbai courts.
   • Expired on 14 July 2023.
2. User Content and Revenue Sharing (UCRS) Agreement (10 February 2023)
   Effective from 1 November 2022. By this arrangement:
   • Zee supplied long‑form AV and music videos to be hosted/distributed on Mohalla’s platforms.
   • Zee retained ownership and control of content.
   • Mohalla paid a fee under agreed terms.
   • The agreement was mutually terminated effective 1 August 2023.
   • It also had an exclusive Mumbai jurisdiction clause.

3.3 Events Leading to the Suit

• In April–June 2023, Zee and Mohalla corresponded about renewing the Licence Agreement. On Mohalla’s failure to renew, Zee wrote on 28 and 30 June 2023, asking Mohalla to remove all Zee content from its platforms from 15 July 2023, following licence expiry on 14 July 2023.
• Mohalla acknowledged these communications and confirmed it would abide by the terms of the Licence Agreement.
• In or around August 2023, during its routine review, Zee discovered that despite expiry/termination of the agreements, Zee’s works were still accessible and being used via the in‑built music libraries on ShareChat and Moj, on a very large scale (approx. 1,395 instances on ShareChat and 8,036 on Moj as per the plaint).
• Zee issued a legal notice on 23 August 2023, demanding immediate cessation.
• On 1 September 2023, Mohalla replied:
  • Denying liability.
  • Claiming immunity as an “intermediary” under Section 2(w) read with Section 79 of the IT Act, 2000.
  • Stating it had removed Zee’s licensed content from its audio library in terms of the Licence and employs rights management tools to identify/take down infringing content.
• Zee alleged that notwithstanding these assertions, its repertoire continued to be available and exploited via the platforms, undermining its revenue and exclusive rights.

3.4 Suit and Interim Order

Zee filed CS(COMM) 745/2023 in the Delhi High Court seeking:

• Permanent injunction restraining infringement of its copyrighted works.
• Ancillary reliefs (damages, rendition of accounts, etc., though the judgment focuses on jurisdiction).

On 1 November 2023, at an interim stage, the Court noted Zee’s statement that:

• It did not object to use of remixes, cover versions, or user‑generated content even if containing elements of Zee’s works, for the time being.
• The only “identified copyrighted content” at that stage was 134 films/clips listed in Schedule 1A of the UCRS Agreement.

The Court ordered Mohalla to ensure that none of these 134 films/clips formed part of its in‑built library accessible on ShareChat and Moj. No injunction was granted against other uses (remixes, covers, UGC) at that stage. Later, Zee filed I.A. 25951/2023 seeking clarification that its interim concession was limited to that date and did not restrict its right to press the suit and injunction against all infringing uses in its repertoire.

4. Detailed Analysis of the Judgment

4.1 Scope of the Suit: Contract vs Statutory Infringement

A critical initial step in the Court’s reasoning is defining the nature of the cause of action. The Court carefully parses the plaint, extracting several key paragraphs (notably paras 3, 18, 22–24, 29, 35, 37).

These passages make clear that:

• Zee complains of “blatant and unauthorized use and exploitation” of its sound recordings and underlying works on ShareChat and Moj via Mohalla’s in‑built music libraries.
• The suit is explicitly framed as one for infringement of intellectual property rights under Section 51 of the Copyright Act.
• Allegations against Mohalla are as an active participant that “intentionally and voluntarily” aids and abets infringement by:
  • Hosting Zee’s works in its music library.
  • Allowing and enabling users to select these works to create videos.
  • Broadcasting these videos on its platforms to the public.
• The pleaded injury is loss of revenue, impairment of exploitation of the repertoire, and encouragement of third parties to create infringing content.

Crucially, the Court notes that:

• There is no pleading of breach of the Licence Agreement or UCRS Agreement.
• No contractual reliefs are sought (such as damages for breach, declaration of rights under the contract, etc.).
• The relevant cause of action is post‑expiry/post‑termination of those agreements: “despite the termination of the User Content and Revenue Sharing Agreement”, Mohalla continued unlicensed use.

On this basis, the Court holds that the subject matter of the suit is a statutory tort (copyright infringement), not a contractual dispute. As a corollary, contractual jurisdiction clauses are not determinative.

4.2 Effect of Exclusive Jurisdiction Clauses in Expired Contracts

Mohalla argued that:

• Both the UCRS Agreement and the Licence Agreement contained clauses giving exclusive jurisdiction to Mumbai courts for disputes “arising out of or in connection with” those agreements.
• The current dispute is “inextricably connected” with the contractual relationship, since it concerns continued exploitation of content earlier licensed under those agreements.
• Hence, even post‑termination, the exclusive jurisdiction clause should govern.

The Court rejects this contention on principle:

• An exclusive jurisdiction clause will apply to disputes which fall within its textual ambit – typically disputes “arising out of” or “in connection with” the contract.
• Here, the plaint does not challenge performance of the contract, nor seek to enforce, interpret, or set aside the agreements. The cause of action is an independent statutory wrong – infringement of copyright – said to have arisen after the agreements expired or were terminated.
• The Court underscores that jurisdiction is determined by the plaint, not the defendant’s characterisation of the dispute (relying on Halsbury’s Laws of India, Vol. 20(1), para 185.381).

In effect, the Court affirms a clear doctrinal proposition:

Where the plaintiff’s cause of action is a statutory IP infringement that does not seek to enforce contractual rights and arises after expiry/termination of the contract, contractual exclusive jurisdiction clauses do not govern the forum for the infringement suit.

This is a meaningful clarification in the growing class of disputes where:

• There are prior IP licences or content deals with exclusive jurisdiction clauses; and
• Subsequent alleged infringement occurs after licences lapse, or in a manner not authorised by them.

4.3 Demurrer Approach under Order VII Rule 10 CPC

The Court reiterates the well‑settled doctrine that an objection to territorial jurisdiction at the Order VII Rule 10 stage is an objection by demurrer.

Demurrer (simplified): The Court assumes, for the sake of argument only, that all facts pleaded by the plaintiff are true, and then asks: “Even if all this is true, does this Court lack jurisdiction as a matter of law?”

Relying on Exphar SA v. Eupharma Laboratories Ltd and M/s RSPL Ltd v. Mukesh Sharma (2016 SCC OnLine Del 4285), the Court notes:

• Only the plaint and documents filed therewith can be looked at.
• The written statement and the defendant’s version are irrelevant at this stage.
• The objection will succeed only if, on the plaint’s own showing, jurisdiction is absent.

The Court also refuses to allow its earlier interim order (1 November 2023) – which dealt with 134 clips identified under the UCRS Agreement – to narrow the scope of the suit for jurisdictional purposes. That order was:

• Based on an interim concession by Zee, expressly limited in time and subject to clarification.
• Not determinative of the nature or breadth of the cause of action as pleaded in the plaint.

Thus, jurisdiction must be tested on the plaint viewed as a whole, not on interim statements or the defendant’s narrative.

4.4 “Carries on Business” and Online Platforms

The plaintiff invoked Section 20(c) CPC, contending that:

• Mohalla Tech carries on business in Delhi through its platforms and websites.
• Its services are targeted to users in Delhi, and infringing content is accessible there.

The Court quotes Halsbury’s Laws of India, Vol. 20(1), para 185.383, on “carries on business”:

There is no indication that the place of carrying on business must be only the principal place of business. […] The plain meaning of the expression only conveys that wherever there is business activity, be it the principal place or branch or branches, the party is said to carry on business in all such places. […]

Applying this logic to online enterprises, the Court relies on Icon Health & Fitness, Inc. v. Sheriff Usman (2017 SCC OnLine Del 10481): where the defendants offer apps and bands via App Stores/e‑commerce portals accessible throughout India, including Delhi, they can be said to be carrying on business in Delhi.

In the present case:

• ShareChat and Moj are accessible from anywhere in India, including Delhi, via downloads or web access.
• Users in Delhi can both:
  • Access content (including alleged infringing content) hosted on the platforms.
  • Create content using the in‑built music libraries and publish it for public viewing.

The Court therefore holds that Mohalla Tech is carrying on business and providing services in Delhi via its digital platforms.

4.5 Copyright Infringement as the Jurisdictional Trigger

4.5.1 Section 51 Copyright Act – When is Copyright “Infringed”?

Section 51(a) of the Copyright Act provides that copyright is deemed infringed when any person, without licence:

• Section 51(a)(i): does anything the exclusive right to do which is conferred on the copyright owner.
• Section 51(a)(ii): permits, for profit, any place to be used for communication of the work to the public where such communication constitutes an infringement.

The plaint alleges that Mohalla:

• Continues to use/broadcast/exploit Zee’s works without licence after expiry of the agreements.
• Provides, via its music library, access to Zee’s songs for users to incorporate into their videos.
• Operates the platforms for profit, thereby permitting a “place” to be used for communication of Zee’s works to the public.

The Court notes that these averments, if accepted, prima facie attract Section 51, and thus form a legally cognisable cause of action in copyright infringement. It draws support from Super Cassettes Industries Ltd v. Punit Goenka (2009 SCC OnLine Del 2407), where continued use by an ex‑licensee post‑expiry was held to constitute infringement.

4.5.2 Where Does the Cause of Action Arise in Online Infringement?

Section 20(c) CPC allows a suit to be instituted in a court within whose jurisdiction the cause of action, wholly or in part, arises.

In copyright cases, the Court cites Burger King Corp. v. Techchand Shewakramani (2018 SCC OnLine Del 10881) to reaffirm:

In a suit involving infringement of copyright, cause of action arises at each and every place where there is copyright infringement.

Additionally, the Court refers to the Allahabad High Court’s decision in Jamp India Pharmaceuticals Pvt Ltd v. Jubilant Generics Ltd (2025 SCC OnLine All 6898), which held that:

• The plaintiff is not obliged to “chase infringers” in every location where infringement occurs.
• Section 62(2) of the Copyright Act read with Section 20(c) CPC enables the plaintiff to sue where it carries on business and where part of the cause of action arises, even if the defendants are situated elsewhere.

Here, the Court finds that:

• Zee alleges that its works are being illegally exploited via Mohalla’s platforms across India, including Delhi.
• Users in Delhi can access the infringing content and can themselves create and upload content using Zee’s works via the in‑built library.
• The alleged infringing activity (communication to the public, making available, synchronisation in new videos) occurs wherever the platform is used interactively – including Delhi.

Therefore, at least part of the cause of action arises in Delhi, satisfying Section 20(c) CPC.

4.6 Website Accessibility, “Targeting”, and the Banyan Tree Line

Mohalla invoked decisions such as:

• Banyan Tree Holding (P) Ltd v. A. Murali Krishna Reddy (2009 SCC OnLine Del 3780)
• Impresario Entertainment & Hospitality Pvt Ltd v. S&D Hospitality (2018 SCC OnLine Del 6392)
• Karans Gurukul Classes v. Gurukul Classes IIT Division (2019 SCC OnLine Del 844)

Those cases, primarily in trademark/passing‑off contexts, developed the doctrine that mere website accessibility in a forum State is insufficient; the plaintiff must show that:

• The website “targets” consumers in that State; and
• There is at least one commercial transaction entered into with a user in the forum State resulting in harm.

The Court distinguishes these precedents on two grounds:

1. Nature of right and cause of action:
   The Banyan Tree line deals with trademark infringement/passing off, where consumer confusion and misrepresentation are integral elements. By contrast, copyright infringement under Section 51 is triggered whenever someone does an act reserved for the copyright owner, regardless of confusion.
2. Type of online activity:
   Here, the platforms are not merely passive informational websites. They:
   • Host and supply copyrighted works in an in‑built music library.
   • Enable users to create derivative content using these works.
   • Communicate this content to the public for profit.
   This is not just “visibility” but interactive exploitation of the works.

The Court also relies on Tata Sons Pvt Ltd v. Hakunamatata Tata Founders (2022 SCC OnLine Del 2968) to reinforce that “targeting” need not be an aggressive marketing strategy; the “looming presence” of an interactive website accessible in the forum State may suffice, depending on the facts.

Further, decisions like RX Infotech Pvt Ltd v. Jalpa Rajesh Kumar Jain (2023 SCC OnLine Del 5345) and Exxon Mobil Corp v. Exoncorp Pvt Ltd (2019 SCC OnLine Del 9193) are deployed to show that:

• Where a defendant operates an interactive e‑commerce or service website allowing online transactions across India, and there is no restriction on transactions from Delhi, it is legitimate to infer that part of the cause of action arises in Delhi.

Thus, the Court holds that even if a specific transaction in Delhi is not pleaded, the combination of:

• Interactive nature of the platforms;
• Availability of Zee’s repertoire in the in‑built music library;
• Ability of Delhi users to access and exploit these works;

is sufficient to establish territorial nexus for a copyright infringement claim.

4.7 Distinguishing Contract‑Centric Precedents Tendered by the Defendant

Mohalla also relied on decisions like:

• Huntsman International (India) Pvt Ltd v. Kleur Speciality Chemicals Pvt Ltd (2018 SCC OnLine Del 11810)
• Saregama India Ltd v. Eros Digital FZ LLC (2017 SCC OnLine Del 10996)

The Court distinguishes these on the basis that:

• In Huntsman, the dispute centred on alleged breach of a confidentiality agreement/contractual obligations, with the alleged breach occurring while the contract subsisted. The jurisdictional analysis was therefore contract‑centric.
• In Saregama v. Eros, the subject matter was similarly a contractual licensing dispute.

In contrast, the present case:

• Does not seek to enforce any contractual rights or obligations.
• Concerns alleged post‑expiry/post‑termination exploitation of IP in violation of statutory rights.

Accordingly, those precedents do not control the jurisdictional analysis here.

4.8 Dominus Litis and the Plaintiff’s Choice of Forum

Reiterating Arcadia Shipping Ltd v. Tata Steel Ltd (2024) 9 SCC 374, the Court underscores the principle of dominus litis:

Section 20(c) CPC accords dominus litis to the plaintiff to institute a suit within the local limits of whose jurisdiction the cause of action, wholly or in part, arises.

Once it is shown that part of the cause of action in copyright infringement arises in Delhi (by virtue of accessibility and alleged exploitation of the works on ShareChat and Moj in Delhi):

• The plaintiff is entitled to choose Delhi as a proper forum.
• The presence of other potential fora (e.g., Mumbai under Section 62(2) Copyright Act or under contracts) does not negate Delhi’s jurisdiction.

The Court also cites Nilesh Girkar v. Zee Entertainment Enterprises Ltd (2025 SCC OnLine Del 6040), where it was held that availability of a film on an OTT platform accessible within the jurisdiction (Saket) sufficed to confer territorial jurisdiction.

5. Complex Concepts Simplified

5.1 “Demurrer” in Jurisdictional Objections

A demurrer is a procedural concept where the defendant says, in effect:

“Even if everything the plaintiff has pleaded is taken to be true, the court still cannot grant relief (here, because it has no jurisdiction).”

For an Order VII Rule 10 objection:

• The court assumes all facts in the plaint are correct.
• If those facts, read legally, bring the case within the court’s jurisdiction, the objection fails.
• This prevents defendants from defeating suits at the threshold by contesting facts that must be decided at trial.

5.2 “Cause of Action” and Section 20(c) CPC

Cause of action comprises every fact that the plaintiff must prove to obtain a judgment. Under Section 20(c):

• If any component of this factual matrix occurs within a court’s territorial limits, that court can entertain the suit.
• In IP cases, every place where the infringing act or its harmful effect occurs constitutes part of the cause of action.

5.3 “Carries on Business” in the Digital Era

Traditionally, a company “carries on business” where it has:

• Its principal office; or
• A branch or subordinate office; or
• A shop/unit that transacts with customers.

With internet‑based businesses, courts now treat:

• Interactive websites
• E‑commerce portals
• Apps offering services across India

as carrying on business wherever they are freely accessible and transact with customers, unless clearly geo‑restricted.

5.4 Difference Between Trademark “Targeting” and Copyright “Availability”

In trademark and passing‑off cases:

• Courts are concerned with consumer confusion and misrepresentation.
• Hence, they have required proof that the defendant’s online activity targets consumers in the forum State and has resulted in at least one transaction there.

In copyright cases:

• The wrong lies in doing any act reserved to the copyright owner, regardless of confusion.
• If infringing works are made available or communicated to the public in a State, that itself is an infringing act in that State.

This judgment clarifies that the stringent “targeting plus transaction” standard of Banyan Tree is not required to establish jurisdiction in copyright infringement arising from interactive platforms.

5.5 Interplay Between Contractual Forum Clauses and Statutory IP Rights

Parties frequently insert clauses such as:

“All disputes arising out of or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts at Mumbai.”

This judgment draws a distinction:

• Covered by clause: Disputes about performance, interpretation, breach, validity, or enforcement of the contract.
• Not necessarily covered: Independent statutory torts (like IP infringement) that:
  • Arise after the contract expires or is terminated; and
  • Do not seek to enforce or challenge contractual rights.

Thus, while parties can choose a forum for contractual disputes, they do not automatically oust statutorily conferred fora for non‑contractual wrongs.

6. Impact and Broader Legal Significance

6.1 For Online Platforms and Intermediaries

• Platforms like ShareChat and Moj, which host content libraries and facilitate user‑generated content incorporating copyrighted works, may face suits in any forum where their platforms are accessible and used, not merely where their registered offices or servers are located.
• The decision underscores that claims of being an “intermediary” under the IT Act do not, at the jurisdictional stage, displace the plaintiff’s allegations of active infringement under Section 51.
• Platform design choices – such as maintaining in‑built music libraries and monetising user‑generated videos – will be scrutinised as potential infringing acts in every State where users operate.

6.2 For Copyright Owners and IP Litigation Strategy

• Copyright owners can sue in fora where:
  • They carry on business (under Section 62(2) Copyright Act); and/or
  • Part of the cause of action arises (Section 20(c) CPC), including where infringing content is accessible and exploited.
• They are not necessarily confined to the contractually chosen forum if the cause of action is framed and substantively arises as a post‑contract statutory infringement.
• The judgment will likely embolden IP owners to sue large online platforms in courts perceived as having stronger IP enforcement, e.g. Delhi, provided the infringing act is accessible there.

6.3 Doctrinal Clarifications on Internet Jurisdiction

The judgment contributes to the evolving Indian jurisprudence on internet‑based jurisdiction:

• It continues the trajectory of cases like Icon Health, Exxon Mobil, and RX Infotech, which treat interactive, commercial websites/apps as purposefully availing jurisdiction in each place of access.
• It explicitly limits the reach of Banyan Tree’s stricter standard to—at least primarily—trademark and passing‑off disputes, confirming a more rights‑specific approach.
• It realigns the analysis with the nature of the right involved—confusion‑based (trademark) versus act‑based (copyright)—rather than imposing a one‑size‑fits‑all test for internet jurisdiction.

6.4 Contract/IP Interface and Forum Clauses

Commercial contracts in media and technology sectors frequently contain detailed jurisdiction and arbitration clauses. This decision:

• Signals that contractual forum clauses will not always be determinative where the cause of action is framed as a distinct statutory IP tort after contract expiry.
• Encourages more careful drafting if parties truly intend to channel all disputes, contractual or tortious, arising from the overall commercial relationship to a particular forum. (Though even then, any attempt to contractually oust statutory fora in certain contexts may face judicial resistance.)

7. Conclusion

The Delhi High Court’s judgment in Zee Entertainment Enterprises Ltd v. Mohalla Tech Pvt Ltd marks an important development in the law of territorial jurisdiction for online copyright infringement.

The Court firmly holds that:

• Where a plaintiff alleges unlicensed exploitation of copyrighted works via interactive online platforms, and these platforms are accessible and used within the territorial limits of a court, part of the cause of action arises there under Section 20(c) CPC.
• The exclusive jurisdiction clauses in prior, now‑expired agreements do not automatically govern subsequent statutory infringement claims that are not pleaded as contractual disputes.
• Jurisdictional objections at the threshold must conform to the demurrer principle: they cannot be sustained where, even accepting the plaint as it stands, the court is shown to have jurisdiction.

By distinguishing between the evidentiary and doctrinal requirements for trademark and copyright cases in the online context, the Court tailors the jurisdictional analysis to the nature of the right and the character of the alleged wrong. The decision strengthens the hand of copyright owners against online platforms that facilitate large‑scale use of their works, while also clarifying that contractual arrangements cannot be used as a blanket shield to divert all related disputes away from forums where infringement actually manifests.

As digital platforms and content licensing arrangements continue to proliferate, this judgment will likely serve as a key reference point for both IP owners and intermediaries, shaping forum selection and pleading strategies in future online infringement litigation.