The Court of Session’s Outer House ruled that Christopher Airlie, who owns and manages the Troll Inn in Dundee, violated the Scottish Professional Football League’s (SPFL) copyright by displaying unauthorized live football broadcasts featuring SPFL-branded graphics on the pub’s televisions. According to the judgment, Airlie had permitted an employee to show Dundee United TV and Celtic TV feeds at the venue in November 2025, despite the content being subject to legal restrictions.
Lord Lake dismissed Airlie’s argument that patrons might have streamed the matches from their phones to the pub’s TVs. The court ruled that an injunction against future copyright violations was warranted, though the case was adjourned before a final decision due to a technical issue with one of the copyrighted works.
Copyright Infringement Allegations
The SPFL sought an injunction against Airlie for copyright infringement related to graphics in video broadcasts of league games. They claimed that on November 9, 2025, these graphics were displayed on TVs at the Troll Inn, constituting public communication under section 20 of the Copyright, Designs and Patents Act 1988.
Airlie neither confirmed the SPFL’s copyright ownership nor the display of the footage. He suggested that if matches appeared on screen, a customer might have streamed them from a phone without staff noticing. However, Lord Lake accepted evidence that the SPFL held copyright to the graphics, created by commissioned suppliers, and deemed them protected artistic works.
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On November 9, inquiry agent Mr. McLean visited the pub and noted that shortly after his arrival, a TV was turned off by the barmaid, irritating customers who then took out their phones. Later, with about 30 people present, two screens were turned on, showing Hearts v Dundee United via Dundee United TV and Celtic v Kilmarnock via Celtic TV.
Authorisation and Liability
Lord Lake found that Airlie had authorised the barmaid’s actions, given his control over staff and knowledge of the previous infringement. The judge also took account of Airlie’s statement that he and staff knew when someone reporting on them had entered because a stranger would order a juice or half pint. This suggested a response designed to conceal what was happening and that the barmaid had been instructed accordingly.
Lord Lake concluded that the SPFL had established infringement of its copyright. Given the earlier undertaking followed by further infringement, it was reasonable to fear recurrence and interdict was justified. The final terms of the order were left for a By Order hearing because Lord Lake identified a drafting problem relating to one of the appendices containing the copyrighted graphics.
In practice, this development means that pub owners and managers may be required to have the necessary permissions and licenses to show live football feeds, and that they may be expected to take steps to prevent the unauthorized use of copyrighted materials. This can involve implementing measures to prevent customers from casting or mirroring matches from mobile phones, as well as ensuring that staff are aware of and comply with copyright laws.
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The SPFL’s head of partnerships, Andrew Sinclair, explained that some matches were broadcast by Sky while others were filmed on the league’s behalf and supplied to member clubs for use on subscription club channels. Media licence agreements prevented commercial use and subscriber agreements restricted the content to residential use. Overseas services were subject to geo-blocking preventing access from the UK and Ireland.
Lord Lake found both SPFL witnesses credible and reliable, and rejected Airlie’s evidence that the televisions could display only free-to-view channels. The judge also regarded it as significant that Airlie had not called the barmaid as a witness or preserved the CCTV footage, which could have provided evidence to support his claim that customers had cast the matches from mobile phones.
Andrew Sinclair, the SPFL’s head of partnerships, explained that users could attempt to circumvent those restrictions using virtual private networks, while IPTV services could also unlawfully “scrape” feeds from legitimate broadcasts.
The SPFL’s solicitors had contacted Airlie 15 days after the inspection, but he did not retain the CCTV footage.
