Recently, The Supreme Court of India issued directions to all States and Union Territories to remove stray dogs from public institutions and relocate them to designated shelters after sterilisation and vaccination.
Comparison with Previous Supreme Court Orders
| Date |
Bench |
Details |
Policy Shift |
| Aug 11, 2025 |
Justices J.B. Pardiwala & R. Mahadevan |
The Supreme Court stray dogs case began with suo motu cognizance of escalating dog bite incidents in Delhi NCR.
- “No-release” Rule: All stray dogs in Delhi-NCR to be captured and permanently housed in shelters.
|
Absolute Removal; Ignored Animal Birth Control (ABC) Rules, 2023 |
| Aug 22, 2025 |
Justices Vikram Nath, Sandeep Mehta, N.V. Anjaria |
Modified approach: Release of sterilized and vaccinated dogs back to their original territories
- It aligned with the scientifically validated Catch Neuter Vaccinate Release (CNVR) model that prevents the ecological vacuum effect where new, potentially aggressive dogs fill vacant territories
|
Humane, Rule-based management. |
| Nov 7, 2025 |
Same three-judge Bench |
New directive for institutional and high-footfall areas only |
Balanced between public safety and animal rights. |
Key Highlights of the November 2025 Supreme Court Order
- Immediate Removal and Relocation: Stray dogs to be removed “forthwith” from educational and healthcare institutions, transit hubs, and other public premises.
- Animals must be sterilised and vaccinated under the Animal Birth Control (ABC) Rules, 2023 before being relocated to shelters.
- They cannot be released back into the same locality.
- Accountability and Enforcement: Local bodies and municipal authorities are responsible for immediate compliance.
- They must submit detailed compliance reports within eight weeks.
- Nodal officers to be appointed in every institution for stray-dog surveillance and maintenance.
- Quarterly inspections mandated to ensure compliance.
- Any lapse will invite personal accountability of officials.
- Infrastructure and Safety Mandates: Institutions must install fencing, boundary walls, and gates to prevent animal ingress.
- State surveys identifying all affected institutions to be completed within two weeks.
- Hospitals must maintain ‘constant stock’ of anti-rabies vaccines.
- Implementation of waste-management systems to eliminate food sources attracting strays.
- Animal Welfare and SOPs: Animal Welfare Board of India (AWBI) to draft Standard Operating Procedures (SOPs) for dog-bite prevention and stray management.
- SOPs must be uniformly applied nationwide.
- Removal of Cattle from Highways
- Extends beyond dogs: SC directs removal of cattle and stray animals from highways and public roads.
- NHAI and municipal bodies to establish 24×7 patrol units, maintain helplines, and ensure relocation to gaushalas or shelters.
- Chief Secretaries and NHAI Chairperson held personally accountable for lapses
The Stray Dog Crisis in India

- Huge National Stray Population: India has over 50 million stray dogs according to the State of Pet Homelessness survey.
- Dog Bite Incidence: In 2024, India recorded 37,17,336 dog bite cases, reflecting the scale of public health and safety concerns linked to the stray population.
- Rabies Impact: According to World Health Organization (WHO) data, India accounts for 36% of global rabies deaths, with 18,000 to 20,000 human rabies cases reported annually.
- The country also reported 54 suspected human rabies deaths in 2024, with the vast majority of rabies cases traced to dog bites.
- Shelter Capacity Gap: Only about 8 million homeless dogs are housed in shelters, leaving the vast majority on the streets without systematic control measures.
- Urban Conflict: The lack of sterilisation and waste management systems has intensified dog–human conflict, particularly around public institutions.
Key Constitutional Provision & Legal/Policy Frameworks
- Constitutional Provision
- Article 51A(g): Fundamental duty of citizens to show compassion for all living creatures.
- Articles 243(W) & 246: Local bodies are responsible for controlling the stray dog population.
- Article 246(3): States manage preservation, protection, and improvement of livestock, prevention of animal diseases, and veterinary training/practice.
- Legal and Policy Frameworks
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- Prevention of Cruelty to Animals Act, 1960 (PCA Act): Section 4 establishes the Animal Welfare Board of India (AWBI) for promoting animal welfare and protecting animals from unnecessary pain or suffering.
- Section 38(1)(ea) and (2) empower the Central Government to make rules for “animal birth control” among other matters.
- The PCA Act provides the foundational legal basis for stray-dog management (via welfare and cruelty prevention) rather than direct municipal control.
- Animal Birth Control Rules, 2023 (ABC Rules 2023): Notified by the Ministry of Fisheries, Animal Husbandry & Dairying under the PCA Act, superseding the earlier ABC (Dogs) Rules, 2001.
- Mandate local bodies (municipal corporations, municipalities, panchayats) to carry out sterilisation, vaccination (anti-rabies), de-worming and post-operative care of stray/community dogs.
- Rule 20 Explicitly Addresses Feeding Of Community Animals: Resident Welfare Associations (RWAs), Apartment Owners’ Associations (AOAs) or local bodies must designate feeding spots and form Animal Welfare Committees
- Emphasise that community dogs be managed in their locality (territory) unless exceptions apply (e.g., rabid/aggressive).
- Judicial Interventions & Recent Developments
- Animal Welfare Board of India v. Nagaraja (2014): SC extended the (Article 21) right to life with dignity to non-human (animals), shaping the jurisprudence on animal rights in India.
- The Court also reiterated the state’s duty to balance human safety with animal welfare.
- Animal Welfare Board of India v. People for Elimination of Stray Troubles (2016–2023):
- Emphasis on existing laws: The Court consistently stressed that the Prevention of Cruelty to Animals Act, 1960 and the ABC Rules provided the exclusive framework for managing stray dogs, emphasizing that any parallel “vigilante activity” was illegal.
- Prohibition of indiscriminate killing: A central theme was that indiscriminate killing of stray dogs was prohibited, and authorities had to act in accordance with the law.
- Requirement for infrastructure: The Court reiterated the duty of local authorities to create necessary infrastructure, such as dog pounds, veterinary clinics, and mobile operation theatres.
- Role of AWBI and local committees: The Court clarified the roles of the Animal Welfare Board of India and local committees in overseeing the implementation of sterilization, vaccination, and euthanasia programs, noting that euthanasia was restricted to critically ill, fatally injured, or rabid dogs.
- Supreme Court (August & November 2025 orders): Directed removal of stray dogs from high-footfall institutional areas (schools, hospitals, stations) but reaffirmed the humane management principles in other areas, balancing citizens’ right to safety with animals’ right to life and dignity.
Reasons for Failure of the Animal Birth Control (ABC) Programme
- Poor Implementation & Governance: Local bodies lack trained staff, coordination, and accountability. The implementation is inconsistent across states.
- Inadequate Infrastructure & Funding: Few functional sterilisation centres, poor post-operative care, and chronic budget shortages cripple large-scale execution.
- Weak Data & Monitoring: No reliable stray-dog census, inflated reporting, and absence of independent audits make outcomes unverifiable.
- Non-Compliance & Legal Confusion: Frequent violations of ABC Rules and contradictory court/municipal directives create administrative paralysis.
- Neglected Root Causes: Open garbage, unregulated feeding, and poor public awareness sustain stray populations despite sterilisation drives.
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Responsibilities & Governance Layers
- Central Government: Enacts rules under PCA Act, issues guidelines/advisories & monitors implementation.
- State Governments / Union Territories: Through animal-husbandry departments, urban development departments, direct implementation oversight; may issue state-specific rules/local amendments.
- Local Authorities (Municipalities, Panchayats): Primary implementation units – Identifying stray dog populations, conducting sterilisation/vaccination drives, designating feeding zones, maintaining shelters and monitoring. The ABC Rules place obligations directly on local bodies.
- Animal-Welfare Organisations (AWOs): Recognised by AWBI under ABC Rules; can be engaged by local authorities to carry out ABC programmes
Key Ethical Aspects Surrounding Stray Dog Management
- Moral Status of Animals: Animal ethics explores whether non-human beings possess intrinsic moral worth or are protected only through human duty.
- Kantian Perspective – Duty and Rational Morality: Immanuel Kant distinguished between beings with intrinsic worth (ends-in-themselves) and those with merely instrumental value (means to an end).
- For Kant, only rational beings (humans) possess autonomous moral will and thus intrinsic moral worth. Animals lack rationality, so they do not have direct moral rights but how we treat them reflects our moral character.
- Jain Philosophy – Ahimsa and Universal Compassion: Jainism’s core principle, Ahimsa (non-violence), extends to all living creatures, recognising the interconnectedness of all life (Jiva).
- Inflicting pain, even on lower beings, is seen as spiritual violence (Himsa) that harms both the victim and the moral integrity of the actor
- Ethically, the Jain approach supports non-lethal, preventive measures such as sterilisation and care rather than extermination — aligning with the ABC framework’s humane foundation.
- Rigvedic Ethos – Harmony and Coexistence: The Rigveda envisions the universe as a single, interdependent order (Ṛta), where all beings ( human and non-human) have rightful places in creation.
- Hymns express gratitude to animals as companions in human sustenance and moral life, implying that dominion entails responsibility, not exploitation.
- Managing stray animals ethically thus becomes an expression of Dharma, preserving harmony and cosmic balance between species.
- Intrinsic Value of Animal Life: Rooted in Animal Welfare Board of India v A. Nagaraja & Ors (2014), animals possess an inherent right to live with dignity.
- Ethical governance requires recognising non-human life as deserving of compassion and freedom from unnecessary suffering.
- Human Safety vs. Animal Rights Dilemma: Dog-bite incidents and rabies deaths raise legitimate public-health concerns.
- Ethically, state action must minimise harm to both humans and animals by avoiding cruelty while ensuring citizen safety.
- Utilitarian Balance and Justice: Policies must achieve maximum welfare with minimum harm, considering both human and animal interests.
- Ethical justice demands protecting vulnerable groups like children and the elderly from attacks, and stray dogs from abuse or starvation.
Parens Patriae
- It is a legal doctrine under which the State acts as the guardian and protector of those unable to care for themselves, such as minors or animals.
- In animal welfare jurisprudence, it means the State has a duty to safeguard animals’ rights and well-being on behalf of society.
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- Stewardship and Responsibility: Under parens patriae, the State acts as a guardian for animals.
- Citizens Share Moral Responsibility: Proper waste disposal, controlled pet ownership, and support for sterilisation programs.
- Community Ethics: Stray management tests civic compassion and coexistence values.
- Feeding bans without designated zones reflect neglect of humane ethics, while unregulated feeding endangers others, both are failures of moral balance.
- Ethical Decision Principles
- Minimise harm: Interventions must avoid unnecessary pain.
- Proportionality: Restrictive actions (capture, relocation) should be no harsher than required for public safety.
- Accountability: Administrators must justify actions through humane reasoning, not convenience or populism.
Measures to Balance Public Safety and Animal Welfare
- Scientific Population Control: Implement ABC Rules 2023 – Sterilisation, anti-rabies vaccination, and de-worming as humane alternatives to culling.
- Establish adequately equipped Animal Birth Control Centres in every district.
- Public-Health Safeguards: Ensure constant supply of anti-rabies vaccines in hospitals. Mandate quick-response protocols for dog-bite management and rabies surveillance.
- Institutional Accountability: Appoint nodal officers in public institutions (as per SC order 2025) and mandate quarterly inspections.
- Require compliance audits by municipal bodies with penalties for negligence.
- Waste and Food-Source Management: Enforce solid-waste rules strictly by eliminating open garbage, a primary food source sustaining stray populations.
- Create designated feeding zones in consultation with RWAs and local authorities.
- Public Awareness and Community Engagement: Promote responsible pet ownership – licensing, vaccination, and sterilisation of pets.
- Educate citizens on dog behaviour, bite prevention, and humane coexistence.
- Data-Driven Monitoring: Maintain centralised stray-dog and rabies databases for evidence-based policymaking.
- Link municipal funding to measurable ABC programme outcomes.
Other Measures to Address the Stray Dog Crisis
- Large-Scale Sterilisation and Vaccination Drives: Replicate Bhutan’s Nationwide Accelerated Dog Population Management and Rabies Control Programme (2021–2023), which achieved 100% sterilisation and vaccination of strays over time.
- Adoption Incentives: Netherlands’ model by imposing high taxes on store-bought dogs and promoting adoption from shelters, reducing street populations sustainably.
- Community-Based Management: Encourage local communities to participate in feeding, vaccinating, and monitoring dogs in their areas, combined with the Collect-Neuter-Vaccinate-Return (CNVR) approach.
- Pet Police : Establish dedicated animal welfare enforcement unit to penalise neglect and abandonment, ensuring pet responsibility and reducing stray numbers.
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Conclusion
A humane state protects both human safety and animal dignity achieving coexistence through law, ethics, and compassion in action.