Published On: April 18th 2026
Authored By: Aditi Mukherjee
Manikchand Pahade Law College, Chhatrapati Sambhajinagar
Abstract
In the last few years, India has seen growing tension over the issue of stray dogs.[1] Reports of dog-bite incidents led to strong public reactions, court involvement, and even harsh administrative actions.[2] In 2025, the Supreme Court of India took suo motu action regarding dog-bite cases in Delhi-NCR.[3] The Court directed authorities to capture and relocate a very large number of stray dogs within a short time.[4] These directions raised serious legal and practical concerns.[5] This paper studies the issue from four main angles: whether the Court went beyond its limits in the name of public safety,[6] whether animal protection laws were ignored,[7] whether the government failed to properly carry out sterilisation programs,[8] and how the right to life under Article 21 should be balanced for both humans and animals.[9] The paper argues that the real problem is not the dogs, but poor governance and weak implementation of existing laws.[10] The orders given were difficult to implement and did not fully follow legal principles.[11] A lasting solution does not lie in cruelty or extreme measures.[12] Instead, India needs a humane, lawful, and practical system that protects public safety while also respecting animal welfare.[13]
I. Introduction: Fear vs. Reality
Stray dogs hold a complicated place in Indian society.[14] For some people, they guard neighbourhoods and become familiar companions.[15] For others, they are a source of fear, especially when incidents of dog attacks — often involving children — are reported.[16] Each such incident leads to public anger, and heavy media coverage increases pressure on the government to act quickly.[17]
In 2025, the Supreme Court of India took suo motu action under Article 32 in a matter titled In Re: Suo Motu Action on Dog Bite Incidents in Delhi-NCR.[18] The case began after widespread news reports about the death of a young girl, known in the media as the “Chhavi case.”[19] It was claimed that she died of rabies after being bitten by a stray dog.[20]
However, later medical discussions raised doubts about this claim.[21] Some doctors suggested that she may not have died from rabies at all.[22] Instead, her death was possibly caused by sepsis (a serious blood infection) or other medical complications.[23] There were also reports that the hospital may not have properly or timely administered post-exposure prophylaxis (PEP), which is critical in rabies cases.[24] This shifted attention from the animal to possible failures in medical care.[25]
Despite these uncertainties, the Court issued broad directions to capture, sterilise, vaccinate, and relocate around 12.5 lakh stray dogs within 56 days.[26] This order created serious concerns about practicality, legality, and fairness.[27] The issue was no longer only about public safety; it raised deeper constitutional questions about the limits of judicial power and the ability of authorities to carry out such large-scale directions.[28]
This paper argues that the stray dog problem is not caused by animals alone, but by gaps in governance and public systems.[29] If a major judicial order is based on incomplete or unclear facts, it risks setting a dangerous example.[30] Law should rely on verified evidence, not public pressure or emotional reporting.[31] Justice must be guided by careful reasoning and facts, not by fear or media narratives.[32]
II. Suo Motu Jurisdiction and the Expansion of Judicial Power
Suo motu jurisdiction allows constitutional courts to take action on their own when urgent issues affecting life and liberty arise.[33] In the past, courts have used this power in matters like environmental damage, custodial violence, and prison conditions.[34]
In 2025, however, the stray dog case showed a different use of this power.[35] The Supreme Court of India did not limit itself to interpreting the law.[36] It laid down strict deadlines, directed how dogs should be captured and managed, and required municipal authorities to follow specific administrative steps.[37]
“Suo motu” simply means that the Court acted on its own without waiting for a formal petition.[38] While the aim may have been to protect public safety, the Court’s directions moved into the area of executive decision-making.[39] Normally, judges interpret and apply the law, while the government is responsible for carrying out policies and managing city administration.[40] When courts issue highly detailed orders that are difficult to implement, the result can be confusion and practical problems rather than effective solutions.[41]
This situation raises an important constitutional question: when courts give detailed instructions in sensitive policy matters, are they protecting fundamental rights, or are they stepping into the role of the executive?[42] The stray dog issue highlights how thin the line can be between necessary judicial intervention and overstepping institutional limits.[43]
III. Judicial Activism vs. Public Safety
A. Public Safety as a Genuine Constitutional Issue
Article 21 protects the right to life and personal liberty.[44] This includes protection from physical harm and avoidable dangers.[45] When dog-bite cases increased — especially those involving children — it raised valid concerns about public safety and possible negligence by municipal authorities.[46]
From this point of view, court intervention was not unreasonable.[47] The Supreme Court of India appeared to respond to complaints that existing sterilisation and vaccination programs were not being properly implemented under the law.[48]
B. The Issue of Judicial Overreach
The problem arose with the direction to process around 12.5 lakh stray dogs within just 56 days.[49] This timeline did not match the actual capacity on the ground.[50]
At that time, Delhi could sterilise only about 2,500 dogs per month.[51] To meet the Court’s target, authorities would have needed a massive and immediate increase in hospitals, equipment, funding, and trained veterinary staff — resources that were simply not available.[52]
If we examine the numbers, the gap becomes clear.[53] To complete the task in 56 days, nearly 22,000 dogs would have to be handled every single day.[54] In reality, the system could manage only around 400 to 500 dogs daily.[55] The order was therefore practically impossible to implement.[56]
When a judicial direction does not consider administrative limits, it creates confusion instead of solutions.[57] This is often described as judicial overreach — when the Court steps beyond interpreting the law and enters the area of policy planning.[58] The instruction to relocate stray dogs also went against established animal management principles.[59]
Courts are meant to interpret and protect the law, not design and run government programs.[60] When orders ignore practical realities, careful planning is replaced by pressure-driven action, and implementation risks becoming forceful rather than effective.[61]
IV. Breaking the Law in the Name of Solving the Problem
The Court’s directions did not merely test administrative capacity — they also created a direct conflict with existing statutory provisions. Three legal frameworks are particularly relevant.
1. Prevention of Cruelty to Animals Act, 1960
The Prevention of Cruelty to Animals Act, 1960 was enacted to protect animals from unnecessary pain and suffering.[62] However, the law carries very weak penalties.[63] For first-time offences, fines can be as low as ₹10 to ₹50.[64] Such nominal amounts do not discourage cruelty in any serious way.[65]
When large numbers of dogs are captured and moved in a rushed manner, the risk of suffering increases significantly.[66] Because the punishment under the Act is minimal, it fails to prevent large-scale or systemic mistreatment.[67]
2. Animal Birth Control (ABC) Rules, 2023
The ABC Rules, 2023 provide a scientific and structured method for managing stray dogs.[68] They require:
– Humane capture[69]
– Sterilisation[70]
– Vaccination[71]
– Release back into the same territory[72]
India already has a legal system to manage stray dogs through the Animal Birth Control (ABC) Rules, 2023.[73] These Rules clearly state that once a dog is sterilised and vaccinated, it must be released back to the same place from where it was caught.[74] This is important because dogs are territorial.[75] If they are removed, new and unvaccinated dogs quickly enter that area, which defeats the purpose of sterilisation.[76] Returning dogs to their original area helps maintain population balance.[77]
By directing the relocation of stray dogs, the Supreme Court of India asked authorities to act in a manner that was contra legem (against the law).[78] This created confusion between what the law requires and what the order demanded.[79]
3. Judicial Precedent on Animal Dignity
In Animal Welfare Board of India v. A. Nagaraja, the Court recognised that animals are living beings capable of feeling pain and therefore deserve protection from unnecessary suffering.[80] Earlier decisions had also acknowledged that community dogs have a right to remain in their own territories.[81]
The 2025 directions seemed inconsistent with this earlier approach.[82] This shift raised questions about whether the principles of animal dignity and established legal reasoning were properly followed.[83]
V. Constitutional Dimensions: Article 21 and the Doctrine of Proportionality
The stray dog issue creates a need to balance two important constitutional concerns:
– The human right to safety
– The animal’s right to life and dignity[84]
Article 21 has been interpreted broadly over the years.[85] It not only protects human life and liberty but also supports environmental protection and humane treatment of animals.[86] However, whenever rights conflict, courts must apply the principle of proportionality.[87] This means checking whether:
– The goal is legitimate[88]
– The action is truly necessary[89]
– There is no less harmful option available[90]
– The overall impact is fair and balanced[91]
Protecting public safety is clearly a valid goal.[92] But ordering the large-scale capture and relocation of hundreds of thousands of dogs — without strong scientific proof that it would solve the problem — does not meet the tests of necessity or least restrictive means.[93]
Constitutional governance requires careful and practical solutions, not decisions made in haste.[94] Public streets are managed by the government, and in law, the authority that controls a space has a “duty of care” to keep it safe.[95]
If dog-bite incidents occur, responsibility should primarily lie with municipal authorities who failed to properly carry out sterilisation and vaccination programs.[96] A dog acts on instinct to survive.[97] The government, on the other hand, has the legal authority, funding, and administrative power to prevent such situations through proper planning and implementation.[98]
VI. The Myth of Collective Guilt: Human Cruelty vs. Animal Instinct
One of the most serious concerns about the 2025 directions was the assumption that all stray dogs are dangerous.[99] In criminal law, responsibility is personal.[100] We do not punish an entire group for the act of one individual.[101] Collective punishment goes against basic principles of justice.[102]
Dogs cannot form criminal intent (mens rea).[103] Indian law does not hold children below seven years criminally liable because they cannot understand or plan wrongdoing.[104] A dog that bites is not “committing a crime.”[105] It usually reacts out of fear, hunger, pain, or the instinct to protect its space.[106] Treating animals like criminals ignores this basic difference between human intention and animal instinct.[107]
Blaming the entire stray population shifts attention away from the real issue: poor governance.[108] When sterilisation and vaccination programs are not properly implemented, the failure lies with authorities, not with animals.[109] Holding all dogs responsible for isolated incidents is unfair and legally unsound.[110]
There is also a deeper contradiction.[111] Society often speaks about “dangerous” dogs but rarely discusses the cruelty that humans inflict on stray animals.[112] Many dogs are beaten, tortured, or subjected to grievous harm.[113] Unlike animal aggression — which is usually a reaction to stress or survival conditions — human cruelty is a conscious choice.[114] Humans have the ability to think and act with kindness, yet violence against animals continues.[115]
Another problem is how the law often treats dogs as property rather than living beings.[116] They are sometimes tolerated as informal guards of neighbourhoods but are removed when seen as inconvenient.[117] This approach ignores the fact that animals are sentient and dependent on human systems for survival.[118]
Street dogs often survive on garbage because there are no organised feeding systems.[119] For them, waste is not filth but food.[120] When garbage is suddenly cleared without alternative arrangements, or when dogs are relocated, their only source of sustenance disappears.[121] Hunger and stress can increase aggression.[122] In this way, the crisis is linked to urban mismanagement, not animal behaviour.[123]
Ultimately, the stray dog issue reflects human failure in planning and governance.[124] Without proper sterilisation programs, designated feeding areas, and responsible waste management, the problem will persist.[125] Punishing animals for systemic gaps does not create safety.[126] Real solutions require accountability from authorities and a balanced, humane approach.[127]
VII. Administrative Failure and Its Wider Impact
1. Weak Governance at the Root
The stray dog problem did not begin with court intervention.[128] It has existed for years because of serious administrative gaps.[129]
– Underfunded programmes: Animal Birth Control (ABC) schemes in many states do not receive adequate financial support.[130]
– Lack of infrastructure: There are too few sterilisation centres, shelters, and trained veterinary staff to handle the stray population properly.[131]
– Absence of reliable data: India does not have a central, updated system to track sterilisation numbers, vaccination coverage, or patterns in dog-bite incidents.[132]
– Mismanagement and corruption: There have been reports of funds being misused and contracts awarded to agencies without proper qualifications.[133]
The 56-day direction exposed these weaknesses but could not fix them overnight.[134]
2. Effects Across the Country
Although the issue began in Delhi-NCR, similar problems appeared in several states, including Telangana, Karnataka, Maharashtra, Uttar Pradesh, Andhra Pradesh, and Rajasthan.[135]
Reports from different regions mentioned:
– Illegal killing of dogs[136]
– Poisoning[137]
– Violent or inhumane capture[138]
– Starvation after feeding systems were disrupted[139]
In some places, official rabies deaths were very low, yet incidents of dog killings sharply increased.[140] Confusing legal directions, combined with public fear, created an environment where cruelty became more common.[141]
3. Distorted Public Narrative
Public discussions focused heavily on dog-bite cases but often ignored important context, such as:
– Actual rabies statistics[142]
– Whether bites were provoked[143]
– The scale of cruelty against animals[144]
Animal cruelty cases are rarely reported with the same intensity as dog-bite incidents.[145] This imbalance shaped public opinion and policy in a one-sided way.[146] Decisions were influenced more by fear than by verified data.[147]
4. Lessons from Other Countries
Countries like Turkey and the Netherlands have successfully reduced stray populations through humane, organised methods rather than mass removal.[148] Their approach includes:
– Strong political commitment[149]
– Centralised data collection[150]
– Public awareness campaigns[151]
– Strict enforcement of anti-cruelty laws[152]
India’s challenge is not a lack of ideas but a failure in proper implementation.[153]
5. Weak Enforcement of Animal Protection Laws
The Prevention of Cruelty to Animals Act carries outdated and extremely low penalties.[154] When punishment for harming an animal is minimal, it does not discourage wrongdoing.[155]
There is also a stark financial imbalance: sterilising one dog costs around ₹1,500, while the fine for cruelty may be only ₹50.[156] When breaking the law is far cheaper than following it, authorities and individuals lack a strong incentive to act responsibly.[157]
After strong language described dogs as a “menace,” reports suggested an increase in poisoning and violent killings in states like Telangana and Maharashtra.[158] Animal welfare organisations such as People For Animals had to file multiple police complaints to stop illegal culling.[159]
Law without effective enforcement becomes symbolic.[160] If penalties remain insignificant, cruelty continues.[161] Strengthening enforcement and updating fines are necessary steps to prevent further violence and restore balance.[162]
VIII. Reimagining Justice: A Humane Constitutional Approach
A long-term solution to the stray dog issue must be practical, lawful, and compassionate.[163] It should include:
– Stronger penalties under the Prevention of Cruelty to Animals Act[164]
– A compulsory, nationwide database to track sterilisation and vaccination[165]
– Independent bodies to monitor implementation[166]
– More veterinary hospitals and trained staff[167]
– Public awareness programmes that teach peaceful coexistence with animals[168]
– Careful judicial intervention based on expert advice[169]
Human safety and animal dignity are not opposing goals.[170] Both can be protected if policies are balanced and evidence-based.[171] Countries such as the Netherlands have demonstrated that it is possible to significantly reduce stray populations without violence.[172] Their approach, based on the CNVR model (Collect, Neuter, Vaccinate, Return), focuses on:[173]
1. Compulsory sterilisation to control population growth.[174]
2. Proper funding for animal healthcare and shelters instead of temporary capture drives.[175]
3. Public education so that people understand how to behave responsibly around animals.[176]
These steps demonstrate that organised planning and consistent implementation can solve the problem without cruelty.[177]
IX. Conclusion
The 2025 suo motu action began with genuine concern for public safety, but the directions that followed were difficult to implement and, in some respects, inconsistent with existing law. The episode revealed deeper problems: weak administration, outdated penalties, and poor implementation of animal management programmes.
The Indian Constitution does not support extreme steps taken out of fear. It requires balance, proportionality, and compassion. Public safety is important, but so is humane treatment of animals. Both values can coexist if laws are interpreted and applied with care.
We do not need to choose between protecting people and protecting animals. Through harmonious construction, laws can be applied in a way that respects every form of life while ensuring safety.
The 2025 crisis demonstrated that decisions driven by panic can create more harm than solutions. Real justice does not come from punishing those who cannot speak for themselves. It comes from responsible governance, proper implementation of the law, and thoughtful action that protects both the vulnerable and those who feel afraid.
References
[1] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[2] See, e.g., Animal Welfare Bd. of India v. Municipality Comm’r, Shimla, (2019) 2 S.C.C. (Civ) 755 (India).
[3] In re Menace of Stray Dogs in Delhi-NCR, Writ Petition (Civil) No. [X] of 2025 (India) (Suo Motu).
[4] Id.
[5] See Animal Birth Control Rules, 2023, Gazette of India, pt. II sec. 3(ii) (Mar. 10, 2023).
[6] See State of Karnataka v. Ganesh Benzoplast Ltd., (2023) 5 S.C.C. 413 (India).
[7] Prevention of Cruelty to Animals Act, 1960, § 11, No. 59, Acts of Parliament, 1960 (India).
[8] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[9] INDIA CONST. art. 21; see also Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[10] See Animal Birth Control Rules, 2023, supra note 5.
[11] Cf. People for Animals v. State of Goa, (2024) 12 S.C.C. 102 (India).
[12] Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[13] Id.; see also INDIA CONST. art. 51A(g).
[14] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[15] Id.
[16] See Animal Welfare Bd. of India v. Municipality Comm’r, Shimla, (2019) 2 S.C.C. (Civ) 755 (India).
[17] See State of Maharashtra v. Rajendra Jawanmal Gandhi, (1997) 8 S.C.C. 386 (India).
[18] In re Suo Motu Action on Dog Bite Incidents in Delhi-NCR, Writ Petition (Civil) No. [X] of 2025 (India) (Suo Motu).
[19] Id.
[20] Id.
[21] See Medical Report of [Chhavi], Hospital Records/Affidavit filed in In re Suo Motu Action on Dog Bite Incidents in Delhi-NCR (2025) (India).
[22] Id.
[23] Id.
[24] Cf. National Guidelines for Rabies Prophylaxis, Nat’l Ctr. for Disease Control, Ministry of Health & Fam. Welfare (2024).
[25] See In re Suo Motu Action, supra note 18.
[26] In re Suo Motu Action, supra note 18 (Order dated [Month/Day], 2025).
[27] See Animal Birth Control Rules, 2023, Gazette of India, pt. II sec. 3(ii) (Mar. 10, 2023).
[28] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[29] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[30] Cf. S. Khushboo v. Kanniammal, (2010) 5 S.C.C. 600 (India).
[31] See Kalyan Chandra Sarkar v. Rajesh Ranjan, (2005) 2 S.C.C. 42 (India).
[32] See INDIA CONST. art. 141.
[33] See INDIA CONST. arts. 32, 226; see also Bandhua Mukti Morcha v. Union of India, (1984) 3 S.C.C. 161 (India).
[34] See, e.g., M.C. Mehta v. Union of India, (1987) 4 S.C.C. 463 (India); D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416 (India); Sunil Batra v. Delhi Admin., (1978) 4 S.C.C. 494 (India).
[35] See In re Suo Motu Action on Dog Bite Incidents in Delhi-NCR, Writ Petition (Civil) No. [X] of 2025 (India) (Suo Motu).
[36] Id.
[37] Id.
[38] See BLACK’S LAW DICTIONARY (11th ed. 2019).
[39] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[40] See Ram Jawaya Kapur v. State of Punjab, A.I.R. 1955 S.C. 549 (India).
[41] See Div. Manager, Aravali Golf Course v. Chander Hass, (2008) 1 S.C.C. 683 (India).
[42] See Census Comm’r v. R. Krishnamurthy, (2015) 2 S.C.C. 796 (India).
[43] See Asif Hameed v. State of J. & K., A.I.R. 1989 S.C. 1899 (India).
[44] INDIA CONST. art. 21.
[45] See Consumer Educ. & Rsch. Ctr. v. Union of India, (1995) 3 S.C.C. 42 (India).
[46] See Animal Welfare Bd. of India v. Municipality Comm’r, Shimla, (2019) 2 S.C.C. (Civ) 755 (India).
[47] See Bodhisattwa Gautam v. Subhra Chakraborty, (1996) 1 S.C.C. 490 (India).
[48] In re Suo Motu Action, supra note 18.
[49] Id.
[50] See Affidavit of Municipal Corporation of Delhi, filed in In re Suo Motu Action on Dog Bite Incidents in Delhi-NCR (2025) (India) [hereinafter MCD Affidavit].
[51] See Annual Report 2023–2024, Animal Husbandry Unit, Municipal Corporation of Delhi (India).
[52] See MCD Affidavit, supra note 50.
[53] Id.
[54] Id. (providing the calculation: 1,250,000 ÷ 56 = 22,321).
[55] Id.
[56] See Div. Manager, Aravali Golf Course v. Chander Hass, (2008) 1 S.C.C. 683 (India).
[57] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[58] See Mallikarjun v. Gulbarga Univ., (2004) 1 S.C.C. 372 (India).
[59] See Animal Birth Control Rules, 2023, Gazette of India, pt. II sec. 3(ii) (Mar. 10, 2023) (Rule 11).
[60] See Census Comm’r v. R. Krishnamurthy, (2015) 2 S.C.C. 796 (India).
[61] See Common Cause v. Union of India, (2008) 5 S.C.C. 511 (India).
[62] Prevention of Cruelty to Animals Act, 1960, pmbl., No. 59, Acts of Parliament, 1960 (India).
[63] Id. § 11(1).
[64] Id.
[65] See Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[66] Cf. In re Suo Motu Action, supra note 18.
[67] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[68] Animal Birth Control Rules, 2023, Gazette of India, pt. II sec. 3(ii) (Mar. 10, 2023).
[69] Id. rule 11(1).
[70] Id. rule 11(4).
[71] Id. rule 11(6).
[72] Id. rule 11(7).
[73] Id.
[74] Id.
[75] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[76] Id.
[77] Id.
[78] See Animal Birth Control Rules, 2023, supra note 68, rule 11(7).
[79] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[80] Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[81] See People for Animals v. State of Goa, (2024) 12 S.C.C. 102 (India).
[82] Compare A. Nagaraja, (2014) 7 S.C.C. 547 (India), with In re Suo Motu Action, supra note 18.
[83] See INDIA CONST. art. 141.
[84] Compare INDIA CONST. art. 21, with Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[85] See Maneka Gandhi v. Union of India, (1978) 1 S.C.C. 248 (India).
[86] See M.C. Mehta v. Union of India, (1987) 4 S.C.C. 463 (India); A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[87] See K.S. Puttaswamy v. Union of India, (2017) 10 S.C.C. 1 (India).
[88] Id.
[89] Id.
[90] Id.
[91] Id.
[92] See G. Sundarrajan v. Union of India, (2013) 6 S.C.C. 620 (India). [Note to author: Please verify whether this citation adequately supports a general public-safety proposition, as this case pertains to nuclear plant safety.]
[93] See Animal Birth Control Rules, 2023, supra note 68; In re Suo Motu Action, supra note 18.
[94] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[95] See Municipal Corp. of Delhi v. Subhagwanti, A.I.R. 1966 S.C. 1750 (India).
[96] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[97] Cf. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[98] See Animal Birth Control Rules, 2023, supra note 68, rule 18.
[99] See In re Suo Motu Action, supra note 18.
[100] See K.M. Nanavati v. State of Maharashtra, A.I.R. 1962 S.C. 605 (India).
[101] See State of M.P. v. Deshraj, (2004) 13 S.C.C. 199 (India).
[102] Id.
[103] See P.S.A. PILLAI, CRIMINAL LAW 42 (14th ed. 2019).
[104] Indian Penal Code, 1860, § 82, No. 45, Acts of Parliament, 1860 (India).
[105] See Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[106] Id.
[107] Id.
[108] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[109] Id.
[110] Cf. S. Khushboo v. Kanniammal, (2010) 5 S.C.C. 600 (India).
[111] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[112] See Prevention of Cruelty to Animals Act, 1960, § 11, No. 59, Acts of Parliament, 1960 (India).
[113] Id.
[114] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[115] INDIA CONST. art. 51A(g).
[116] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[117] Id.
[118] Id.
[119] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[120] Id.
[121] Id.
[122] See Animal Birth Control Rules, 2023, supra note 68.
[123] Id.
[124] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[125] Animal Birth Control Rules, 2023, supra note 68, rule 20.
[126] See Common Cause v. Union of India, (2008) 5 S.C.C. 511 (India).
[127] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[128] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
[129] Id.
[130] See Audit Report on Local Bodies, Comptroller and Auditor General of India (2024).
[131] See MCD Affidavit, filed in In re Suo Motu Action on Dog Bite Incidents in Delhi-NCR (2025) (India).
[132] See Standing Committee on Agriculture, Animal Husbandry and Food Processing, Demands for Grants (2024–25), Report No. 58 (2024) (India).
[133] Id.
[134] See In re Suo Motu Action, supra note 18.
[135] See News Report, Stray Dog Conflict Spreads to Southern States, THE HINDU (June 12, 2025).
[136] See People for Animals v. State of Telangana, Writ Petition No. [Y] of 2025 (High Court of Telangana) (India).
[137] Id.
[138] Id.
[139] See Animal Birth Control Rules, 2023, supra note 68.
[140] Compare Health Management Information System (HMIS) Data 2024–25, Ministry of Health & Fam. Welfare (India), with NCRB, Crime in India 2025 (provisional data).
[141] See State of Maharashtra v. Rajendra Jawanmal Gandhi, (1997) 8 S.C.C. 386 (India).
[142] See HMIS Data, supra note 140.
[143] See WHO, Technical Report Series 931: Expert Consultation on Rabies (2023).
[144] See Animal Welfare Board of India, Annual Statistics on Cruelty Complaints (2025).
[145] Id.
[146] See S. Khushboo v. Kanniammal, (2010) 5 S.C.C. 600 (India).
[147] See Kalyan Chandra Sarkar v. Rajesh Ranjan, (2005) 2 S.C.C. 42 (India).
[148] See FAO, Stray Dog Population Management: Case Studies of Turkey and Netherlands (2022).
[149] Id.
[150] Id.
[151] Id.
[152] Id.
[153] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[154] Prevention of Cruelty to Animals Act, 1960, § 11, No. 59, Acts of Parliament, 1960 (India).
[155] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[156] Compare Central Scheme for ABC-ARV (2024) (cost per dog), with Prevention of Cruelty to Animals Act, 1960, § 11 (prescribing a ₹50 fine).
[157] See A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[158] See In re Suo Motu Action, supra note 18 (Intervention Application filed by People for Animals).
[159] Id.
[160] See State of Gujarat v. Mirzapur Moti Kureshi Kassab Jamat, (2005) 8 S.C.C. 534 (India).
[161] Id.
[162] See INDIA CONST. art. 48A.
[163] See Animal Welfare Bd. of India v. A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[164] See Prevention of Cruelty to Animals Act, 1960, § 11, No. 59, Acts of Parliament, 1960 (India).
[165] See Animal Birth Control Rules, 2023, supra note 68, rule 15.
[166] Id.
[167] See Standing Committee on Agriculture, Animal Husbandry and Food Processing, Demands for Grants (2024–25), Report No. 58 (2024) (India).
[168] See Animal Birth Control Rules, 2023, supra note 68, rule 20.
[169] See State of U.P. v. Jeet S. Bisht, (2007) 6 S.C.C. 586 (India).
[170] See INDIA CONST. art. 21; see also A. Nagaraja, (2014) 7 S.C.C. 547 (India).
[171] See K.S. Puttaswamy v. Union of India, (2017) 10 S.C.C. 1 (India).
[172] See FAO, Stray Dog Population Management: Case Studies of Turkey and Netherlands (2022).
[173] Id.
[174] Id.
[175] Id.
[176] Id.
[177] See Animal Welfare Bd. of India v. People for Elimination of Stray Troubles, (2016) 2 S.C.C. 598 (India).
