if you have a good camera (2x number of pixels, and 2x colordepth than the movie), then you could make a camrip with perfect quality (assuming some calibration frames, and a cinema that gives no fuck). https://en.wikipedia.org/wiki/Nyquist%E2%80%93Shannon_sampling_theorem
though I guess that's still too much effort for most, and most early leaks are digital copies, as the other comments suggest.
edit: newer comments suggest camrip with a bad camera