Full Judgment Text
2026 INSC 506
REPORTABLE
IN THE SUPREME COURT OF INDIA
INHERENT/CIVIL ORIGINAL/
EXTRAORDINARY APPELLATE JURISDICTION
SUO MOTO WRIT PETITION(CIVIL) NO(S). 5 OF 2025
IN RE: “CITY HOUNDED BY STRAYS, KIDS PAY
PRICE”
WITH
SLP(CIVIL) NO(S). 14763 OF 2024
SLP(CIVIL) NO(S). 17623 OF 2025
WRIT PETITION(CIVIL) NO(S). 784 OF 2025
SLP(CIVIL) Diary No. 45707 OF 2025
T.C. (CIVIL) NO. 140 OF 2025
CONTEMPT PETITION (C) NO(S). 749 OF 2025 IN
SLP(CIVIL) NO(S). 14763 OF 2024
T.C. (CIVIL) No. 147/2025
Signature Not Verified
Digitally signed by
NEETU KHAJURIA
Date: 2026.05.19
16:21:12 IST
Reason:
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J U D G M E N T
Mehta, J.
For clarity of exposition and to facilitate structured
consideration of the issues arising in the present
matter, this judgment has been organised under the
following heads: -
5
INDEX
I. INTRODUCTION ............................................................... 7
II. PART I: CONSIDERATION OF INTERLOCUTORY
APPLICATIONS SEEKING MODIFICATION, CLARIFICATION,
VACATION, RECALL AND/OR STAY OF DIRECTIONS ISSUED
TH
VIDE ORDER DATED 7 NOVEMBER, 2025 ......................... 20
1. S UBMISSIONS ADVANCED ON BEHALF OF THE A PPLICANTS
SEEKING M ODIFICATION , C LARIFICATION , V ACATION , R ECALL
TH
AND / OR S TAY OF D IRECTIONS ISSUED VIDE ORDER DATED 7
OVEMBER ........................................................... 22
N , 2025: -
A. Alleged Conflict of the Impugned Directions with the
Animal Birth Control Rules, 2023 ................................. 22
B. Prayer for Constitution of a Technical/Expert
Committee for Comprehensive Evaluation of the Issues
Involved ......................................................................... 26
C. Financial, Logistical, and Infrastructural
Constraints in Implementation, including Expenditure
towards Creation of Shelters, Deployment of Personnel,
and Maintenance of Stray Animals ............................... 29
D. Deficiencies in Implementation and Enforcement of
the Animal Birth Control Framework by State and
Municipal Authorities .................................................... 34
UBMISSIONS ADVANCED ON BEHALF OF THE PPLICANTS
2. S A
TH
SUPPORTING THE D IRECTIONS ISSUED VIDE ORDER DATED 7
N OVEMBER , 2025 AND SEEKING THEIR CONTINUATION AS WELL AS
EXTENSION TO OTHER PUBLIC AND INSTITUTIONAL AREAS : - ..... 37
3. C ONSIDERATION AND A NALYSIS OF THE S UBMISSIONS
A DVANCED BY THE P ARTIES : - .............................................. 46
A. Scope and Applicability of the Animal Birth Control
Rules, 2023 in Relation to Institutional and Restricted-
Access Premises ............................................................. 47
6
B. Exercise of Jurisdiction under Article 142 of the
Constitution of India and Validity of the Directions Issued
59
C. Examination of Ancillary Contentions Raised on
Behalf of the Applicants ................................................ 78
D. Accountability and Tortious Liability in the Context
of Stray Dog Management ............................................. 86
4. C ONCLUSION : - .......................................................... 90
III. PART II: CONSIDERATION OF INTERLOCUTORY
APPLICATIONS CHALLENGING THE STANDARD OPERATING
PROCEDURE ISSUED BY THE ANIMAL WELFARE BOARD OF
INDIA IN COMPLIANCE OF DIRECTION (J) CONTAINED IN
TH
ORDER DATED 7 NOVEMBER, 2025 ................................. 91
IV. PART III: STATUS OF COMPLIANCE BY THE STATES AND
UNION TERRITORIES WITH THE DIRECTIONS ISSUED BY THIS
COURT ................................................................................ 99
ANNEXURE: COMPLIANCE REPORTING FORMAT
(STATES/UTS) ................................................................... 130
I. INTRODUCTION
1. This Court, vide its detailed and comprehensive
th 1
order dated 7 November, 2025 , upon an exhaustive
consideration of the compliance affidavits filed by
various States and Union Territories, the summary
report submitted by the learned Amicus Curiae , as
well as the news reports highlighting the escalating
incidents of stray animal intrusions and dog-bite
cases across the country, was persuaded to
1
City Hounded by Strays, Kids Pay Price, In re , (2026) 1 SCC 774.
7
supplement, modify and further elaborate upon the
th
earlier directions issued vide orders dated 11
nd
August, 2025 and 22 August, 2025. The Court took
judicial notice of the grave and continuing threat
posed by the unchecked presence of stray animals,
both on public roads, more particularly on National
Highways and National Expressways, and within
institutional premises such as educational
institutions, hospitals, sports complexes, bus
stands/depots (including Inter-State Bus Terminals)
2
and railway stations , where such incidents have
been reported with alarming frequency, thereby
posing a serious risk to the safety of students,
patients, staff and the general public. The Court
observed that the persistence of such preventable
hazards reflects systemic administrative lapses and a
lack of effective coordination among the concerned
authorities, and unequivocally underscored that
such circumstances directly impinge upon and
violate the fundamental right to life and safety
guaranteed under Article 21 of the Constitution of
India.
2
Hereinafter, being referred to as “institutional areas”.
8
2. The Court further noted that the underlying
causes of this persisting menace were multifaceted,
arising from factors such as the uncontrolled
reproduction of stray dogs due to inadequate
implementation of sterilisation programmes,
improper disposal of food waste in and around public
institutions, absence of effective perimeter
management coupled with lack of coordination
between institutional authorities and municipal
bodies, and insufficient public awareness regarding
preventive conduct as well as appropriate post dog-
bite medical procedures, thereby necessitating a
comprehensive, coordinated and sustained
institutional response rather than isolated or
ad hoc
measures.
3. Recognising the systemic inadequacies in the
enforcement of existing statutory frameworks,
3
including the Animal Birth Control Rules, 2023 , and
the evident lack of coordinated administrative action,
this Court proceeded to issue a set of uniform and
binding pan-India directions. These directions were
structured to ensure not only the immediate
3
For short, “ABC Rules, 2023”.
9
mitigation of risks arising from the presence of stray
cattle/animals on highways and expressways, but
also to address, in a focused and institutional
manner, the growing menace of stray dogs within
sensitive public spaces such as educational
institutions, hospitals, sports complexes, bus
stands/depots and railway stations. The Court
emphasised the need for accountability, inter-
departmental coordination, and sustained
monitoring mechanisms at both the State and local
levels.
4. In particular, and of critical significance, is the
direction issued under Paragraph 25(E) of the order
th
dated 7 November, 2025, wherein this Court
imposed a clear and mandatory obligation upon the
jurisdictional municipal bodies/authorities to
forthwith remove all the stray dogs found within the
precincts of such identified institutional areas and to
relocate the same to designated shelters, after
ensuring due sterilisation and vaccination in
accordance with the applicable statutory framework.
Importantly, and with a view to securing the effective
implementation of its directions, the Court expressly
prohibited the re-release of such stray dogs into the
10
very same locations from where they were removed,
observing that any such reintroduction would defeat
and frustrate the object and efficacy of the directions
so issued, which were specifically intended to secure
institutional spaces and safeguarding the safety,
health, and well-being of the public at large.
5. For the sake of ready reference, the relevant
extracts from the said order are reproduced
hereinbelow: -
“ PART II: Modification, Application and
Implementation of the Directions issued by
High Court of for Rajasthan at Jodhpur in D.B.
Civil Writ Petition No. 14726 of 2025.
8. It is a matter of grave and continuing public
concern that accidents caused by cattle and other
stray animals on public roads and highways have
become alarmingly frequent across the country.
Such incidents, often resulting in loss of human life,
grievous injuries, and damage to property, are not
isolated events but symptomatic of a larger failure
on the part of the administrative authorities
entrusted with public safety. The uncontrolled
presence of cattle and stray animals on National
Highways, National Expressways, and State
Highways, constitutes a serious and avoidable
threat, particularly during night-time or in high-
speed zones.
9. This Court cannot remain unmindful of the
preventable nature of these accidents, which not
only reflect administrative indifference but also
undermine the constitutional guarantee of the right
to life and safety under Article 21. The need for
immediate, coordinated, and sustained action by all
concerned agencies, i.e., municipal authorities, road
11
and transport departments, public works
departments and highway authorities, cannot be
overstated.
10. Accordingly, this Court issues the following
directions: -
A. The directions issued by the High Court of
Rajasthan at Jodhpur in D.B. Civil Writ
Petition No. 14726 of 2025 vide order dated
11th August, 2025, are hereby reaffirmed, to
the extent that the municipal authorities,
road and transport department/Public Works
Department of all the States and Union
Territories and the National Highways
Authority of India (NHAI) shall ensure the
removal of all cattle and other stray animals
from the State Highways, National Highways,
and National Expressways falling within their
respective jurisdictions.
B. The concerned authorities, i.e., the municipal
authorities, the road and transport
department/Public Works Department of all
the States and Union Territories and the
National Highways Authority of India shall
undertake a joint, coordinated drive to
identify stretches of highways and
expressways where stray cattle or animals are
frequently found, and shall take immediate
steps for their removal and relocation to
designated shelters. The cattle and other stray
animals so picked up shall be kept in appropriate
shelters or Gaushalas/cattle pounds, as the case
may be, and provided with all necessary food,
water, and veterinary care, in accordance with
the provisions of the Prevention of Cruelty to
Animals Act, 1960 and the Animal Birth Control
(Dogs) Rules, 2023.
C. Each authority shall constitute dedicated
highway patrol teams and/or assign existing
road-safety units for continuous surveillance
and immediate response to reports of stray
cattle or other animals obstructing the
12
roadways. Such patrols shall function on a
24x7 basis and coordinate with local police
stations, veterinary officers, and municipal
authorities/Panchayati Raj institutions.
D. All National Highways, State Highways, and
National Expressways shall have prominently
displayed helpline numbers at regular
intervals, enabling commuters to promptly
report the presence of stray animals or
accidents caused thereby. These helplines
shall be linked to the control rooms of the
local police, National Highways Authority of
India, and district administration for real-
time redressal and monitoring.
E. The Chief Secretaries of all States and Union
Territories, together with the Chairperson,
National Highways Authority of India, shall
ensure strict enforcement of these directions
through appropriate administrative orders and
field-level monitoring. They shall hold the
concerned officers personally accountable for
lapses or recurring incidents in their respective
jurisdictions.
F. The aforesaid directions shall be implemented
uniformly across India, and the Chief Secretaries
of all States and Union Territories; Chairperson,
National Highways Authority of India; and
Ministry of Road Transport and Highways, Union
of India shall file status-cum-compliance
affidavits within a period of eight weeks from
today, indicating: -
i. the mechanism established for removal and
sheltering of stray animals from highways;
ii. the constitution and functioning of patrol
teams; and
iii. the operational status of helpline facilities
and installation of sign boards displaying
helpline numbers.
11. The Registry shall forthwith implead the
National Highways Authority of India through its
Chairperson.
13
PART III: Directions regarding Institutional
Areas, i.e., educational institutions, hospitals,
sports complexes, bus stands/depots and
railway stations
12. In the interregnum, this Court has been
apprised through various news reports and media
accounts of disturbing increase in dog-bite incidents
within the premises of educational institutions,
hospitals, sports complexes, bus stands/depots
(including Inter-State Bus Terminals) and railway
stations, generically speaking, institutional areas.
Instances of children being attacked in school
campuses, patients and attendants being bitten
within hospital compounds, athletes as well as
officials being attacked by stray dogs inside sports
stadiums and passengers/travellers being attacked
by stray dogs inside sports stadiums and
passengers/travellers being attacked by stray dogs
at bus stands/depots and railway stations, have
come to the notice of this Court.
13. The recurrence of such incidents, particularly
within institutional spaces meant for learning,
healing, and recreation, reflects not only
administrative apathy but also a systemic failure to
secure these premises from preventable hazards.
The situation calls for immediate judicial
intervention to safeguard the fundamental right to
life and safety of citizens, especially children,
patients, and sportspersons, under Article 21 of the
Constitution of India.
[…..]
15. Recognising the need for a humane yet
effective framework, the Government of India, in
exercise of its powers under the Prevention of
Cruelty to Animals Act, 1960, promulgated the
Animal Birth Control Rules, 2001, subsequently
amended and supplemented from time to time.
These Rules established the Capture-Sterilize-
Vaccinate-Release (CSVR) model as the principal
method for controlling the stray dog population,
thereby prohibiting indiscriminate culling of stray
14
dogs and mandating municipal authorities to
manage sterilisation, vaccination, and sheltering in
coordination with animal welfare organisations.
However, the implementation of these Rules has
been ineffective, to say the least, across
jurisdictions and the persistence of stray dog
population has continued to imperil public safety
in many parts of the country.
[…..]
22. The Court notes that the underlying
causes of this enduring menace are multifaceted,
including, (i) uncontrolled reproduction of stray
dogs owing to inadequate implementation of
sterilisation programmes; (ii) improper disposal
of food waste in and around public institutions;
(iii) absence of effective perimeter management
and institutional coordination with municipal
authorities; and (iv) lack of widespread public
awareness regarding preventive conduct and
post dog bite medical procedures.
23. Despite the statutory framework of the
Animal Birth Control Rules, 2001 as amended in
2023, and the existence of various municipal bye-
laws/guidelines/Standard Operating Procedures,
the practical outcomes have remained suboptimal.
The data emerging from several States and Union
Territories reveal a year-on-year increase in reported
dog bite cases, many occurring within or near public
institutions. The persistence of the problem calls for
a holistic and coordinated approach involving
municipal corporations, public health authorities,
and administration of the institutions, to ensure
that the constitutional mandate of safeguarding the
right to life under Article 21 is not compromised by
administrative inaction or inefficiency.
24. The menace of dog bites, particularly in
public and private institutions that serve as
spaces of learning, healing and recreation, thus
constitutes not merely a public health challenge
but a matter of human safety concern. The State
and its instrumentalities bear an affirmative
15
obligation to ensure that no citizen, least of all
children, elderly people and patients, are
exposed to preventable injury or disease within
public premises.
IV. Directions
25. Having regard to the alarming rise in incidents
of dog bites within institutional areas such as
educational institutions, hospitals, sports
complexes, bus stands/depots (including inter-State
Bus Terminals) and railway stations, this Court
deems it appropriate to issue the following directions
in the interest of public safety, health, and
management of stray dogs: -
A. The State Governments and Union Territories
shall through their respective local/municipal
authorities, within a period of two weeks,
identify all Government and private
educational institutions, hospitals (including
district hospitals, primary health centres, and
medical colleges), public sports complexes or
stadia, bus stands/depots (including Inter-
State Bus Terminals) and railway stations
situated within their territorial limits.
B. The administrative heads of the aforesaid
institutions shall through their respective
local/ municipal authorities, under the
overall supervision of the District Magistrate
concerned, ensure that the premises are
secured by adequate fencing, boundary walls,
gates and such other structural or
administrative measures as may be necessary
to prevent the ingress of stray dogs. The said
exercise shall be completed as soon as
possible and preferably within a period of 8
weeks from today.
C. The management of every educational
institution, hospital, sports complex, bus
stand/depot (including Inter-State Bus
Terminal) and railway station identified under
Direction (A) shall designate a Nodal Officer
responsible for the upkeep and cleanliness of
16
the premises and for ensuring that stray dogs
do not enter or inhabit the campus. The
details of the said officer shall be displayed
prominently at the entrance and notified to
the jurisdictional municipal body/authority.
D. The local municipal authorities and panchayats
shall carry out regular inspections, at least once
in every three months, of all such premises to
ensure that no stray dog habitats exist within or
in the immediate vicinity of these institutions.
Any lapse in this regard shall be viewed seriously,
and responsibility shall be fixed upon the
concerned municipal officials/administrative
authorities.
E. It shall be the responsibility of the
jurisdictional municipal body/authority to
forthwith remove every stray dog found
within the premises of an educational
institution, hospital (public or private), sports
complex, bus stand/depot (including Inter-
State Bus Terminal) or railway station and to
shift such animal/s to a designated shelter,
after due sterilisation and vaccination, in
accordance with the Animal Birth Control
Rules, 2023. The stray dogs so picked up shall
not be released back to the same location from
which they were picked up. We have
consciously directed the non-release of such
stray dogs to the same location from which
they were picked up, as permitting the same
would frustrate the very effect of the
directions issued to liberate such institutional
areas from the presence of stray dogs.
F. All Government and private hospitals shall
maintain a mandatory stock of anti-rabies
vaccines and immunoglobulin at all times.
G. Every school and educational institution shall be
directed by the Ministry of Education,
Government of India, to conduct awareness
sessions for students and staff on preventive
17
behaviour around animals, first-aid in case of
bites, and immediate reporting protocols.
H. The management of stadiums and sports
complexes shall ensure the deployment of
security or ground-keeping personnel
specifically tasked with around the clock vigil
against the entry or habitation of stray dogs.
I. The railway authorities having jurisdiction
over the railway stations as well as the State
transport corporations and municipal
authorities having jurisdiction over bus
stands, depots and Inter- State Bus Terminals,
shall ensure that such public-transport
premises/facilities are effectively secured and
maintained so as to prevent the habitation or
movement of stray dogs within their
premises. Proper waste-management systems
shall be implemented to eliminate food
sources that attract animals, and regular
inspections shall be conducted to detect and
address the presence of stray dogs.
J. Animal Welfare Board of India shall, within
four weeks, issue detailed Standard Operating
Procedures (SOPs) for prevention of dog bites
and management of stray dogs in institutional
premises (public or private) including but not
limited to Government and private
educational institutions, hospitals (including
district hospitals, primary health centres, and
medical colleges), and sports complexes or
stadia, to be uniformly adopted across all
States and Union Territories.
26. The aforesaid directions are being issued in
continuation of and in furtherance of this Court’s
order dated 22nd August, 2025, to ensure that the
menace of stray dog attacks within institutional
areas is curbed through effective preventive and
administrative mechanisms. The primary objective
is to safeguard the fundamental right to life and
safety of citizens, particularly children, students,
patients, and sportspersons, while ensuring
18
compliance with the principles embodied in the
Animal Birth Control Rules, 2023 framed under the
Prevention of Cruelty to Animals Act, 1960.
29. The Union of India shall also ensure that the
aforesaid directions are implemented in respect
of all institutional areas falling under its
administrative or supervisory control, including
Central Government educational institutions,
hospitals, colleges, universities, sports
complexes and railway stations managed by or
affiliated with Central Ministries or authorities
such as the Ministry of Health and Family
Welfare; Ministry of Education; Ministry of
Fisheries, Animal Husbandry and Dairying;
Ministry of Youth Affairs and Sports; Ministry of
Road Transport and Highways; Ministry of
Railways; Ministry of Panchayati Raj; Ministry of
Rural Development and other allied
departments. The Union of India, through the
Ministry of Health and Family Welfare, shall file
a comprehensive affidavit of compliance within
a period of 8 weeks from today, indicating the
steps taken to secure such institutions, the
mechanism evolved for coordination with
local/municipal authorities, and the measures
adopted for ensuring the availability of anti-
rabies vaccines and immunoglobulin in Central
Government hospitals and healthcare facilities.
30. Animal Welfare Board of India shall also file a
consolidated report indicating the nationwide status
of sterilisation and vaccination drives, as well as the
formulation of uniform Standard Operating
Procedures for the prevention of dog-bite incidents
in institutional areas/premises within 8 weeks from
today.”
[Emphasis supplied]
19
II. PART I: Consideration of Interlocutory
Applications Seeking Modification, Clarification,
Vacation, Recall and/or Stay of Directions Issued
th
vide Order Dated 7 November, 2025
6. Subsequent to the passing of the aforesaid order
th
dated 7 November, 2025, a large number of
interlocutory applications came to be instituted
before this Court by various animal welfare
organisations, associations, and individuals
professing concern for the welfare of stray dogs, inter
alia , seeking impleadment and intervention in the
present proceedings. Several of the said applications
also sought for modification, clarification, vacation,
recall and/or stay of certain directions contained in
the said order, particularly those pertaining to the
removal of stray dogs from institutional areas and the
prohibition on their re-release at the same locations.
7. At the same time, certain applications have also
been filed supporting the directions issued vide order
th
dated 7 November, 2025 and seeking expansion of
the said directions to other areas, including gated
housing societies, housing complexes, parks, and
other public places frequented by the public at large.
20
8. The applicants, in support of their respective
prayers, advanced a range of submissions founded
upon statutory provisions, existing regulatory
frameworks, and established principles governing
animal welfare. These submissions have brought to
the fore a set of competing considerations that
warrant careful judicial scrutiny. The applications,
thus, raised issues lying at the intersection of public
safety and animal welfare, necessitating a considered
determination by this Court. In the aforesaid
circumstances, this Court is enjoined to strike a
careful and principled balance between the
constitutional imperative of safeguarding human life
and safety under Article 21 of the Constitution of
India and the statutory mandate of ensuring humane
treatment and protection of animals.
9. In view of the multiplicity of applications and
the diverse reliefs sought therein, it becomes
necessary for this Court to delineate the contours of
the present adjudication. Given that a substantial
number of the interlocutory applications seek
modification, clarification, vacation, recall and/or
th
stay of the directions contained in the order dated 7
November, 2025, this Court considers it appropriate
21
to first address the submissions advanced in support
of such prayers, as well as the submissions advanced
by those applicants supporting the said directions
and seeking their continuation and expansion, in
order to comprehensively examine the competing
perspectives in a structured and cohesive manner.
1. Submissions advanced on behalf of the
Applicants seeking Modification, Clarification,
Vacation, Recall and/or Stay of Directions
th
issued vide order dated 7 November, 2025: -
A. Alleged Conflict of the Impugned Directions
with the Animal Birth Control Rules, 2023
10. Learned senior counsel and other counsel
appearing for the applicants submitted that the
th
directions contained in the order dated 7 November,
2025, insofar as they mandate the removal of stray
dogs from the institutional areas and prohibit their
re-release at the original locations, are in direct
contravention of the statutory framework governing
the management of stray dog population, as codified
under the ABC Rules, 2023, read with the Revised
Animal Birth Control Module for Street Dog
Population Management, Rabies Eradication,
Reducing Man-Dog Conflict issued by the Animal
22
Welfare Board of India. It was contended that the
impugned directions, by requiring permanent
relocation of dogs, effectively supplant the existing
statutory regime, which comprehensively regulates
the manner in which stray dogs are to be managed.
11. It was further submitted that the ABC Rules,
2023 provide a detailed and exhaustive protocol
governing every stage of stray dog population
management, including humane capture, pre-
operative care, sterilisation, vaccination and post-
operative rehabilitation. Particular emphasis was
placed on Rule 11(19) of the said Rules, which
mandates that sterilised and vaccinated dogs shall be
released back into the same locality from where they
were captured. Learned counsel contended that this
requirement is not merely procedural but constitutes
a core component of the statutory scheme, and that
any direction mandating relocation or non-release at
the original site would be inconsistent with, and
derogatory to the express provisions of the ABC
Rules, 2023.
12. Elaborating further, it was submitted that the
statutory mandate of release into the original
territory is founded upon well-established scientific
23
and ecological principles, as recognised in the
Revised Module issued by the Animal Welfare Board
of India. It was contended that removal or
displacement of dogs from a given territory creates a
“vacuum effect”, leading to migration of unsterilised
and unvaccinated dogs into the vacated area, thereby
increasing territorial conflicts, dog bites, and the risk
of spread of rabies. Learned counsel submitted that
such relocation, far from mitigating the problem, may
aggravate human-animal conflict and undermine the
very objective of population stabilisation sought to be
achieved under the Animal Birth Control framework.
13. It was also contended that the ABC Rules, 2023
represent the culmination of sustained judicial
consideration and expert consultation, and embody a
conscious legislative policy favouring the Capture-
Sterilise-Vaccinate-Release (CSVR) model as the only
scientifically validated and humane method of
managing population of stray dogs and eradicating
rabies. In this regard, reliance was placed on the
National Action Plan for Dog Mediated Rabies
Elimination (NAPRE), which, according to the
applicants, reinforces the centrality of maintaining a
stable, sterilised dog population in a given area,
24
rather than resorting to displacement or
confinement.
14. Learned counsel further submitted that, in the
absence of any challenge to the vires of the ABC
Rules, 2023, the directions issued by this Court
ought not to override or operate in derogation of a
binding statutory framework. It was contended that
although this Court exercises plenary powers under
Article 142 of the Constitution of India, such powers
cannot be invoked to supplant substantive law or to
issue directions that are plainly inconsistent with
express statutory provisions occupying the field. In
this regard, reliance was placed on the Constitution
Bench judgment of this Court in Prem Chand Garg
4
v. Excise Commr. , wherein it was held that the
power under Article 142(1) of the Constitution of
India cannot be exercised to make an order which is
inconsistent with or in direct contravention of
statutory provisions or substantive law, much less in
violation of constitutional limitations. It was thus
urged that the ABC Rules, 2023, having statutory
force and embodying a specific legislative policy for
4
1962 SCC OnLine SC 37.
25
the management of population of stray dogs, cannot
be overridden by judicial directions which mandate a
course of action contrary to the express scheme of the
Rules, particularly the requirement of release of
sterilised and vaccinated dogs to their original
locations. On this premise, learned counsel
submitted that the directions mandating non-release
of stray dogs to their original locations are liable to be
suitably modified or clarified so as to bring them in
conformity with the statutory regime under the ABC
Rules, 2023.
B. Prayer for Constitution of a
Technical/Expert Committee for
Comprehensive Evaluation of the Issues
Involved
15. Learned senior counsel and other counsel
appearing for the applicants submitted, at the outset,
that the applicants do not dispute the seriousness of
dog-bite incidents or the corresponding obligation of
the State to ensure the safety and security of the
public at large. However, it was contended that
measures such as indiscriminate removal, large-
scale confinement, or elimination of community dogs
are neither contemplated under the existing statutory
26
framework nor the same is supported by established
scientific principles or India’s civilisational ethos of
humane coexistence. It was urged that such
measures, if implemented without a calibrated and
evidence-based approach, may in fact aggravate the
very problem sought to be addressed by creating
ecological imbalances and increasing human-animal
conflict.
16. It was further submitted that the issue at hand
is complex, multi-dimensional, and resource-
intensive, involving considerations of public health,
urban governance, animal welfare, infrastructure,
and financial capacity of local authorities. Learned
counsel contended that the implementation of the
th
directions contained in the order dated 7 November,
2025, particularly those requiring removal and
relocation of stray dogs to shelters, presupposes the
existence of adequate infrastructure such as
designated shelters, trained personnel, veterinary
support, and sustained funding, which, according to
the applicants, are presently lacking in several parts
of the country. In this backdrop, it was urged that a
uniform, pan-India solution cannot be effectively
27
devised or implemented without the benefit of expert
inputs and stakeholder consultation.
17. In these circumstances, learned counsel
submitted that it would be appropriate for this Court
to constitute an expert committee comprising
representatives of relevant ministries, municipal
authorities, veterinary experts, public health
professionals, and recognised animal welfare
organisations, so as to undertake a holistic and data-
driven assessment of the issue and to suggest
practicable, legally sustainable, and long-term
pathways for managing the presence of community
dogs, particularly within institutional areas. It was
contended that such a committee would
meaningfully assist this Court by providing domain-
specific expertise and coordinated inputs, thereby
enabling the evolution of a calibrated, balanced, and
effectively implementable framework that addresses
public safety concerns while remaining consistent
with statutory mandates and principles of humane
treatment of animals.
28
C. Financial, Logistical, and Infrastructural
Constraints in Implementation, including
Expenditure towards Creation of Shelters,
Deployment of Personnel, and Maintenance
of Stray Animals
18. Learned senior counsel and other counsel
appearing for the applicants submitted that the
feasibility of implementing the directions contained
th
in the order dated 7 November, 2025 must be
assessed in the backdrop of the existing
infrastructural deficiencies across the country,
particularly within educational institutions. It was
contended that a substantial proportion of such
institutions lack even basic facilities, with official
data indicating that tens of thousands of schools do
not have access to electricity, drinking water or
sanitation, and several lakh institutions lack digital
and infrastructural support. These systemic
shortcomings, it was urged, demonstrate the limited
institutional capacity to undertake any additional
and resource-intensive operational responsibilities
such as the removal, transportation and long-term
management of community dogs.
29
19. It was further submitted that the burden of
implementation would primarily fall upon municipal
bodies and urban local authorities, which are already
functioning under severe financial and
administrative constraints. Learned counsel referred
to financial assessments indicating that most
municipal bodies are unable to meet even their
existing revenue-expenditure obligations from
internal sources and remain dependent on often
irregular and insufficient transfer of funds from State
Governments. In such circumstances, it was
contended that requiring these authorities to
conceive, establish, and sustain large-scale
sheltering infrastructure for a significant number of
dogs, along with their long-term maintenance and
care, would be manifestly beyond their existing
administrative wherewithal and fiscal capacity.
20. Elaborating on the scale of the exercise
contemplated, learned counsel submitted that the
implications of the directions are extremely wide in
their sweep, as they encompass a vast number of
institutional spaces across the country, including
educational institutions, hospitals, sports
complexes, bus stands/depots and railway stations.
30
By way of illustration, it was contended that there are
over 15,46,941 educational institutions in India, and
even on a conservative estimate of approximately 10
dogs per institution, the directions would entail the
relocation and permanent housing of over 1.5 crore
dogs from educational institutions alone. When
similar considerations are extended to other
categories of institutional premises across urban,
semi-urban and rural areas, the overall number of
animals requiring relocation and long-term care
would increase exponentially.
21. It was further submitted that accommodating
such an enormous population of stray dogs across
the institutional areas would necessitate the
establishment of more than 77,000 shelters, even on
a conservative estimate of 200 dogs per facility, along
with the acquisition of extensive tracts of land
spanning thousands of acres. Learned counsel
contended that this would also require the creation
of an extensive, nationwide logistical framework
involving coordinated mechanisms for identification,
capture, transportation, medical treatment, record-
keeping and long-term management of animals,
supported by trained personnel and continuous
31
administrative oversight. It was urged that the
magnitude, complexity and permanence of such an
exercise render it unprecedented and far beyond the
scope of existing institutional and governmental
capacities.
22. Learned counsel further submitted that the
financial implications of such an exercise would be
staggering and wholly disproportionate to the
available public resources. It was contended that the
capital expenditure required for acquisition of land
and construction of shelter facilities on the scale
contemplated would run into several thousand crores
of rupees. In addition to this substantial upfront cost,
even a conservative estimate of Rs.40/- per dog per
day towards food alone would result in an annual
recurring expenditure exceeding Rs.22,000 crores,
assuming the scale of relocation envisaged. It was
further submitted that the said estimate pertains
only to basic sustenance and does not account for the
significant additional expenditure that would
necessarily be incurred towards veterinary care,
medicines, sterilisation, vaccination, staffing,
maintenance of facilities, waste management
systems, utilities, transportation, monitoring
32
mechanisms, and administrative oversight. Learned
counsel contended that when these components are
factored in, the total financial outlay would increase
manifold, placing an unsustainable burden on the
public exchequer. In such circumstances, it was
urged that the implementation of the impugned
directions, in their present form, is economically
unviable and incapable of being carried out in a
uniform and effective manner across jurisdictions,
particularly by municipal authorities and local bodies
already operating under severe financial constraints.
23. It was also contended that, in the absence of
adequate infrastructure and financial resources, the
combined effect of mandatory removal, prohibition on
re-release, and lack of sheltering capacity may place
municipal authorities in situations of practical
impossibility, leading to a real and serious risk of
unlawful practices, including culling or mistreatment
of community dogs. Learned counsel therefore
submitted that a more sustainable and legally
compliant approach would be to prioritise
strengthening of sanitation systems, waste
management practices, and effective implementation
of the Animal Birth Control framework, which
33
addresses the underlying causes of human-dog
conflict without imposing disproportionate financial
and logistical burdens on municipal authorities,
urban local bodies and other implementing agencies
entrusted with the execution of these directions.
D. Deficiencies in Implementation and
Enforcement of the Animal Birth Control
Framework by State and Municipal
Authorities
24. Learned senior counsel and the other counsel
appearing for the applicants submitted that the
present controversy does not proceed on the premise
of asserting any absolute “right” of stray dogs to
occupy public streets, but is confined to opposing
their indiscriminate removal from their natural
habitat in a manner that is contrary to statutory
provisions, scientific principles, and humane
considerations. It was contended that the applicants
fully endorse the Animal Birth Control framework,
which itself contemplates regulated management of
community dogs, and that the real issue lies not in
the inadequacy of the statutory regime, but in its
deficient and inconsistent implementation by the
concerned municipal and State authorities.
34
25. It was further submitted that the continued
presence of large numbers of stray dogs on streets is
a direct consequence of the failure of municipal
authorities to effectively implement the Capture-
Sterilise-Vaccinate-Release (CSVR) model envisaged
under the ABC Rules, 2023. Learned counsel
contended that underfunded, sporadic and partial
execution of sterilisation and vaccination
programmes has rendered the framework ineffective
in practice, even though the underlying scientific
methodology has been globally recognised as the
most effective means of controlling the population of
stray dogs, reducing dog-bite incidents, and
eliminating rabies.
26. In support of the efficacy of the Animal Birth
Control framework, learned counsel submitted that
wherever the ABC Rules, 2023, have been
implemented in a sustained and scientifically
compliant manner, it has yielded demonstrable and
measurable results. By way of illustration, it was
pointed out that in Dehradun, where a structured
Animal Birth Control programme was implemented
in collaboration with local authorities, dog-bite
incidents have reportedly reduced by over 68% over
35
a period of time. It was also submitted that the
applicants and associated organisations have
undertaken large-scale sterilisation and vaccination
efforts across multiple municipalities, covering
several lakh dogs, and have conducted systematic
population surveys in cities such as Delhi,
Ahmedabad, Mumbai and Lucknow, thereby
demonstrating the viability and effectiveness of the
statutory model when properly executed.
27. It was thus contended that the persistence of
the stray dog issue is not attributable to any inherent
flaw in the ABC Rules, 2023, but rather to the lack of
adequate infrastructure, funding, and administrative
commitment on the part of implementing authorities.
Learned counsel submitted that instead of resorting
to measures such as mass removal or long-term
confinement of dogs, which are inconsistent with the
statutory scheme, efforts ought to be directed
towards strengthening and scaling up the Animal
Birth Control programme by establishing adequate
sterilisation centres, ensuring availability of trained
personnel, and providing necessary financial and
logistical support.
36
28. In this regard, it was urged that a coordinated,
adequately funded, and rigorously monitored
implementation of the Animal Birth Control
framework, complemented by active community
participation and strengthened urban management
practices such as effective waste management and
sanitation, would provide a far more sustainable,
legally compliant, and scientifically sound solution to
the issue of stray dog population and human-animal
conflict, as opposed to the measures contemplated
under the impugned directions, which, it was
contended, do not address the root causes of the
problem and may yield counterproductive outcomes.
2. Submissions advanced on behalf of the
Applicants supporting the Directions issued
th
vide order dated 7 November, 2025 and
seeking their continuation as well as extension
to other public and institutional areas: -
29. Learned senior counsel and other counsel
appearing for the applicants supporting the
th
directions submitted that the order dated 7
November, 2025 constitutes a necessary, timely and
constitutionally justified intervention to address a
grave, pervasive and escalating public safety crisis
37
arising from the unchecked presence of stray dogs in
public and institutional spaces. It was contended
that the existing Animal Birth Control framework,
which has been in operation since 2001, has not only
failed to achieve its core objectives of effective
population control and reduction of human-dog
conflict, but has, in fact, resulted in a steady and
alarming proliferation of the stray dog population
across the country, thereby exacerbating risks to
public health, safety and mobility.
30. It was further submitted that despite the
extensive efforts for full implementation of the Animal
Birth Control framework, the stray dog population in
India has risen exponentially, from an estimated 2.5
crore in the early 2000s to nearly 8 crores at present,
leading to a deepening and widespread public health
and safety emergency of gargantuan proportions.
Learned counsel pointed out that India continues to
account for the highest number of dog-bite incidents
and rabies-related fatalities globally, with major
hospitals reporting an overwhelming and ever-
increasing caseload of dog attack victims each year,
placing an immense burden on public healthcare
system. It was contended that such empirical data
38
and ground realities unequivocally establish the
inadequacy and ineffectiveness of the existing
sterilisation-and-release model, which, instead of
mitigating risks, has miserably failed to arrest
population growth or meaningfully reduce incidents
of attacks and disease transmission, thereby posing
a continuing and serious threat to human life and
health.
31. Learned counsel further submitted that the
continued release, feeding and maintenance of stray
dogs in public spaces, as contemplated under the
ABC Rules, 2023, has resulted in systemic and
widespread infringement of the fundamental rights of
citizens at large under Article 21 of the Constitution
of India. It was contended that the right to life
encompasses not only mere survival but also the
right to live with dignity in an environment which is
safe, secure, hygienic, free from threats to life,
mobility and livelihood. Learned counsel emphasised
that this Court has, in a catena of judgments,
expanded the scope of Article 21 to include rights
such as safe public spaces, unobstructed movement,
peaceful sleep, and protection from health hazards
and public nuisance, all of which are directly
39
impacted by the unchecked presence of stray
animals.
32. It was further submitted that the presence of
large numbers of free-roaming dogs in public areas,
including roads, parks, residential complexes and
institutional premises, creates a continuous and
pervasive risk of attacks, disease transmission
(including rabies), obstruction of pathways, and
disruption of daily life, thereby impeding the exercise
of fundamental rights. Learned counsel contended
that such conditions particularly affect children,
elderly persons, persons with disabilities, and
economically weaker sections, who are
disproportionately vulnerable and often lack access
to timely medical intervention. It was urged that the
cumulative effect of such conditions results in a
denial of equal and meaningful access to public
spaces, thereby undermining the constitutional
guarantee of life and personal liberty under Article 21
of the Constitution of India.
33. It was further contended that a proper and
harmonious construction of the provisions of the
ABC Rules, 2023 does not support the proposition
that stray dogs have an indefeasible right to occupy
40
or remain within all categories of premises, including
institutional or gated areas. Learned counsel
submitted that Rule 7(2) of the said Rules, which
classifies “street dogs” or “community owned dogs”
including those found within gated campuses, is
merely a classificatory provision and cannot be
construed as conferring any perpetual or enforceable
right upon such animals to inhabit such premises
indefinitely. It was further urged that Rule 11(19),
which provides for release of dogs to their original
locality, must be read in consonance with the parent
statute, namely the Prevention of Cruelty to Animals
5
Act, 1960 . In this regard, reliance was placed on the
definition of “street” under Section 2(i) of the PCA Act,
1960, which confines the expression to public spaces
such as roads, lanes, passages and other areas
accessible to the public. It was therefore contended
that the term “locality” occurring in Rule 11(19) must
be interpreted to mean such “street” or public areas
alone, and cannot be extended to include private
premises, institutional campuses, or controlled-
access spaces such as hospitals, colleges and other
5
For short, “PCA Act, 1960”.
41
similar establishments. On this basis, learned
counsel submitted that the statutory scheme does
not mandate, nor can it be interpreted to require, the
continued presence or reintroduction of stray dogs
within institutional premises or similar restricted
areas, which poses great threat to the stakeholders of
these sensitive areas, and that the directions issued
by this Court are, in fact, consistent with and
constitute a proper interpretation of the governing
statutory framework.
34. It was also contended that the issue extends
beyond public safety and has wide-ranging
ecological, environmental and economic
consequences of a serious magnitude. Learned
counsel submitted that stray dogs have emerged as a
significant threat to wildlife, with studies indicating
attacks on a large number of species, including
several that are classified as threatened and critically
endangered, thereby contributing to the disruption of
fragile ecosystems and biodiversity loss. It was
further submitted that in rural and semi-urban
areas, stray dogs have started to indulge in
systematic livestock predation, including attacks on
sheep, goats and poultry, resulting in recurring and
42
measurable economic losses for farmers and
economically vulnerable communities. Learned
counsel contended that the unchecked proliferation
of stray dogs also leads to ecological imbalance and
increased pressure on native species, and alteration
of natural predator-prey dynamics, thereby
exacerbating environmental stress in both urban and
rural landscapes. It was, therefore, urged that the
issue must be viewed not merely as one of public
safety but as a matter of broader environmental and
socio-economic concern, warranting a
comprehensive, and scientifically grounded
regulatory response.
35. In this backdrop, learned counsel submitted
that the directions issued by this Court for removal
of stray dogs from institutional areas ought not only
to be amplified and also expanded to other public
spaces such as public parks, gated housing societies
and residential complexes, as well as other areas of
high human congregation including marketplaces,
pedestrian zones and recreational spaces, where
similar risks to human safety and public order exist.
It was contended that such areas, by virtue of dense
and continuous human activity, presence of
43
vulnerable populations such as children, elderly
persons and daily commuters, particularly require
protection from the hazards posed by free-roaming
animals, including risks of attacks, spread of disease,
obstruction of movement and disturbance of public
order. It was further urged that the absence of
regulatory control in such spaces leads to the
formation of territorial dog packs, thereby increasing
the likelihood of aggressive behaviour and human-
animal conflict.
36. It was further submitted that globally accepted
models of dog population management do not permit
unrestricted presence of unowned dogs in public
spaces, and instead emphasise upon regulated
ownership, strict control measures, impounding of
stray animals, and, where necessary, humane
euthanasia of dangerous or unclaimed dogs. It was
contended that these models are designed not only to
ensure animal welfare but also to prioritise public
safety, urban hygiene and ecological balance.
Learned counsel therefore contended that a
calibrated framework incorporating such measures,
consistent with public safety imperatives, would
better serve both human interests and principles of
44
responsible animal welfare, as opposed to the
existing regime which, according to the applicants,
fosters unregulated presence of stray dogs in public
spaces without adequate accountability or control
mechanisms.
37. In conclusion, it was urged that the directions
issued by this Court represent a necessary and
constitutionally grounded intervention towards
restoring the primacy of human rights, public safety
and preservation of other endangered species, which,
it was submitted, must remain paramount under
Article 21 of the Constitution of India. It was further
contended that the scope of these directions ought to
be suitably broadened and extended so as to
comprehensively address the menace of stray dogs
not only within institutional areas but also across
other public and residential spaces such as parks,
streets, gated housing societies and residential
complexes, where similar risks to life, mobility and
public health persist, while ensuring that any
measures adopted remain humane, lawful and
effectively implemented.
45
3. Consideration and Analysis of the Submissions
Advanced by the Parties: -
38. We have bestowed our anxious consideration to
the rival submissions advanced on behalf of the
applicants, both seeking modification, clarification,
vacation, recall and/or stay of the directions and
supporting their continuation and expansion. Upon
a careful perusal of the pleadings, documents and
material placed on record, we now proceed to
examine the issues that arise for determination. The
task before us is to strike a careful and principled
balance between competing considerations, namely,
the imperative of safeguarding the fundamental
rights of public at large under Article 21 of the
Constitution of India, including the right to life, safety
and meaningful access to public spaces, and the
statutory mandate of ensuring humane treatment
and management of stray animals in accordance with
the prevailing legal framework. Accordingly, the
analysis that follows evaluates the legality, scope,
efficacy and practical implications of the directions
th
issued vide order dated 7 November, 2025 so as to
determine their conformity with constitutional
principles, statutory provisions and the requirements
46
of effective implementation, in the light of these
competing concerns.
A. Scope and Applicability of the Animal Birth
Control Rules, 2023 in Relation to
Institutional and Restricted-Access Premises
39. At the outset, it is evident from the submissions
advanced that the principal and foremost thrust of
the submissions advanced on behalf of the applicants
seeking modification, clarification, vacation, recall
th
and/or stay of the order dated 7 November, 2025
was that the directions issued by this Court, insofar
as they prohibit the re-release of stray dogs captured
from institutional areas to the same place or location
from where they were removed, are contrary to and
inconsistent with Rule 11(19) of the ABC Rules, 2023,
which mandates that sterilised and vaccinated dogs
shall be released back to their original place or
locality from where they were picked up. It was thus
contended that the impugned directions transgress
and are in derogation of the statutory scheme
governing the management of community dogs. It
was also the fervent caution of the proponents that
the directions so given run contrary to the statutory
provisions. In this backdrop, the principal issue that
47
arises for consideration before this Court is whether
stray dogs found within public institutions such
as educational institutions, hospitals, sports
complexes, bus stands/depots (including Inter-
State Bus Terminals) and railway stations can be
regarded as “street dogs” or “community dogs”
within the classification as provided under Rule
7(2) of the ABC Rules, 2023, so as to entitle them
to the benefit of re-release to the same place or
location from where they were picked up under
Rule 11(19) thereof, or whether such public
institutions fall outside the contemplation of
“same place” or “locality” as envisaged under
Rule 11(9) of the said Rules, thereby making
them ineligible for re-release .
40. For the purpose of examining the aforesaid
issue, it becomes necessary to advert to the relevant
statutory provisions governing the field. In the first
instance, Rule 7(2) of the ABC Rules, 2023 provide
for the classification of animals and, ,
inter alia
recognise “street dogs” or “community owned dogs”
as those which are homeless and are found living
either on streets or, within gated campuses. This
classification assumes relevance in identifying the
48
category of animals to which the regulatory
framework applies. Secondly, it is necessary to
consider the definition of the term “street” as
contained in Section 2(i) of the PCA Act, 1960, which
circumscribes the expression to public spaces such
as roads, lanes, passages and other areas to which
the public has access. The conjoint reading of these
provisions is material for determining the scope and
meaning of the expression “same place” and “locality”
under Rule 11(19) of the ABC Rules, 2023,
particularly in the context of whether such
expression extends beyond public streets to include
institutional or restricted-access premises. For the
sake of ready reference, the relevant provisions are
reproduced hereinbelow: -
“ Rule 7 of the ABC Rules, 2023
7. Classification of animals: - Animals
classified for the purpose of these rules are as under:
[…..]
(2) Street dogs or community owned Indian dogs
or abandoned pedigreed dogs which are
homeless, living on the street or within a gated
campus.
Rule 11(19) of the ABC Rules, 2023
11. Capturing or sterilisation or immunisation or
release: -
[…..]
49
(19) The dogs shall be released at the same place
or locality from where they were captured and
the date, time and place of their release shall be
recorded after their complete recovery and the
representative of the local authority or of the
animal welfare organisation shall accompany the
team at the time of release and from time to
time, the Board may provide a suitable
application for geo-tagging the location of the
dogs during capture and release.
Section 2(i) of the PCA Act, 1960
2. Definitions. ― In this Act, unless the context
otherwise requires, ―
[…..]
(i) “street” includes any way, road, lane, square,
court, alley, passage or open space, whether a
thoroughfare or not, to which the public have
access.”
[Emphasis supplied]
41. Upon a careful examination of the relevant
provisions, we are of the considered view that a
proper and harmonious construction of the
provisions of the Animal Birth Control Rules, 2023,
when read in conjunction with the parent enactment,
namely the Prevention of Cruelty to Animals Act,
1960, does not support the proposition that stray
dogs possess an indefeasible or absolute right to
occupy or remain within all categories of spaces or
premises, irrespective of their nature or use. The
provisions must be interpreted in a purposive and
50
contextual manner, having regard to the object and
scheme of the legislation. The scheme of the ABC
Rules, 2023, properly understood, is regulatory in
character, intended to facilitate humane
management of stray dog populations, including
their control, sterilisation, vaccination and regulated
presence in appropriate public areas, and cannot be
elevated to confer a perpetual or unqualified right of
existence upon such animals in every location where
they may be found, particularly in spaces where
considerations of public safety, health and
institutional functioning assume significance.
42. At the outset, it must be noted that Rule 7(2) of
the ABC Rules, 2023, which classifies “street dogs” or
“community owned dogs” as those that are homeless
and are found living on streets or within a gated
campus, is merely a classificatory provision. Its
purpose is to identify and demarcate categories of
animals for the limited purpose of regulation,
management and application of the statutory
framework, which is directed towards scientific
control and stabilisation of the canine population in
the interest of safeguarding public health and safety
and not to create or recognise any substantive or
51
vested right in favour of such animals to continue
occupying those spaces indefinitely. The provision is
thus descriptive in nature and not declaratory of any
enforceable entitlement. A classification provision, by
its very nature, cannot be construed and interpreted
to be a source of enforceable rights, much less one
that overrides considerations of public safety,
institutional integrity, or statutory limitations,
particularly where such an interpretation would
defeat the object and purpose of the PCA Act, 1960
and the ABC Rules, 2023 themselves.
43. It must also be noted that while including “gated
campus” within the ambit of Rule 7(2) of the ABC
Rules, 2023, the rule-making authority could not
have contemplated a situation where stray dogs are
permitted to inhabit and roam around in sensitive
institutional premises such as hospitals, schools,
colleges, sports complexes, airports and similar
establishments. The expression “gated campus” must
be understood in a limited and contextual sense, and
cannot be expansively construed to cover all
categories of controlled-access institutional spaces,
particularly those where safety, hygiene and
regulated activity are of paramount importance. Such
52
locations are frequented by large numbers of
persons, including children of tender age, patients,
elderly individuals and other vulnerable sections of
society, who are inherently more susceptible to risks
arising from presence of animals, including attacks,
disease transmission and disruption of essential
services. Furthermore, by their very nature,
institutions such as hospitals, schools, colleges,
sports complexes, airports and similar
establishments are required to be sterile and free
from all kinds of obstructions and intrusions. The
presence of stray dogs in such environments not only
poses serious safety and health hazards but may also
impede the proper functioning of these institutions,
which are designed to serve critical public purposes.
The inclusion of “gated campus” in the classification
clause, namely, Rule 7(2) of the ABC Rules, 2023,
therefore, cannot be read in a manner that legitimises
or perpetuates the presence of stray dogs in such
sensitive and high-risk spaces, nor can it be
interpreted to override the obligation of the State and
municipal/local authorities to ensure safe, secure
and hazard-free institutional environments.
53
44. Further, Rule 11(19) of the ABC Rules, 2023,
which mandates the release of sterilised and
vaccinated dogs to the same place or locality from
where they were picked up, must necessarily be read
in a manner consistent with the parent statute. The
PCA Act, 1960, being the source of delegated
authority, circumscribes the scope within which
subordinate legislation must operate, and any
interpretation of the Rules must remain within the
contours of the enabling statute. In this context, the
definition of “street” under Section 2(i) of the PCA Act,
1960 assumes considerable significance, as it
expressly limits the expression to public spaces such
as “any way, road, lane, square, court, alley, passage
or open space, whether a thoroughfare or not”, to
which the public has access. This definition, being
provided under the principal enactment, must guide
and inform the interpretation of expressions used in
the subordinate legislation framed thereunder. This
statutory definition therefore provides an important
interpretative guide for understanding the scope and
ambit of the expression “same place or locality” used
in Rule 11(19) of the ABC Rules, 2023, and indicates
that the same cannot be construed in a manner that
54
travels beyond the concept of publicly accessible
spaces as contemplated under the parent statute.
45. When Rule 11(19) of the ABC Rules, 2023, is
read in light of the aforesaid definition, it becomes
evident that the expression “same place or locality”
cannot be construed in an unbound or expansive
manner so as to include private premises,
institutional campuses, or controlled-access spaces
such as hospitals, colleges and similar
establishments. To do so would be to disregard the
statutory context, the scheme of the parent
enactment, and the clear legislative intent underlying
the use of the term “street” in Rule 7(2) and would
effectively extend the operation of the ABC Rules,
2023 beyond their intended domain. The term “same
place or locality” must therefore be confined to public
streets and other analogous open-access areas to
which the public has unhindered access, where the
regulatory balance between animal management and
public interaction is contemplated, and where the
statutory scheme can be effectively implemented
without compromising public safety or institutional
integrity.
55
46. This interpretation is further reinforced by the
nature and function of institutional and restricted-
access premises. Spaces such as educational
institutions, hospitals, transport hubs and other
public utility areas are designed for specific purposes
involving the safety, health and movement of large
numbers of people, often including vulnerable
groups. These premises are expected to maintain a
controlled, secure and hygienic environment, where
human safety measures are to be maintained at the
optimum level and all risk factors have to be
eliminated. To read the Rules as mandating the
continued presence or reintroduction of stray dogs in
such spaces would be contrary to the very purpose
for which these premises exist, and would create a
direct, unavoidable, and irreconcilable conflict
between statutory interpretation and the
constitutional imperative of ensuring public safety in
such environments, thereby resulting in serious
practical and administrative difficulties in the
discharge of their core functions.
47. Moreover, a contrary interpretation, which
treats the presence of stray dogs in all locations as a
matter of right, would lead to serious, anomalous and
56
manifestly impractical consequences. It would
effectively deprive authorities of the ability to exercise
necessary regulatory control or take preventive
measures to restrict the presence of animals in
sensitive or high-risk areas, even where such
presence poses clear, immediate and demonstrable
risks to public safety, health, or institutional
functioning. This would, in effect, result in a situation
where administrative authorities are rendered
helpless to discharge their statutory and
constitutional obligations towards ensuring safety
and order in public and institutional spaces. Such an
outcome could not have been intended by the rule-
making authority and would render the regulatory
framework internally inconsistent, operationally
unworkable, and incapable of effective enforcement
in real-world conditions.
48. In view of the foregoing discussion, it must be
held that the statutory scheme underlying the PCA
Act, 1960, and the Rules framed thereunder, namely,
the ABC Rules, 2023, does not mandate, nor can it
be interpreted to require, the continued presence or
compulsory reintroduction of stray dogs within
institutional premises or other restricted-access
57
areas. Consequently, stray dogs found within such
institutional spaces or similar controlled
environments, including educational institutions,
hospitals, sports complexes, airports, bus
stands/depots (including Inter-State Bus
Terminals) and railway stations cannot be held to
fall within the scope of the classification
contemplated under Rule 7(2) of the ABC Rules,
2023, i.e., “street dogs” or “community owned
dogs,” inasmuch as the said provision, read in
conjunction with Rule 11(19) of the ABC Rules,
2023, cannot be construed to extend to sensitive
or restricted premises of this nature.
49. In the aforesaid view of the matter, we reiterate
and affirm the directions issued by this Court vide
th
order dated 7 November, 2025, insofar as they
exclude such premises from the operation of re-
release under Rule 11(19) of the ABC Rules, 2023,
and hold that the same are in consonance with a
proper, purposive and harmonious interpretation of
the governing statutory framework, and serve to align
the implementation of the ABC Rules, 2023 not only
with the statutory scheme but also with the practical
realities obtaining in such spaces, with due regard to
58
considerations of public safety, institutional integrity
and constitutional obligations.
B. Exercise of Jurisdiction under Article 142 of
the Constitution of India and Validity of the
Directions Issued
50. Having considered the statutory framework
governing the present controversy, this Court must
now advert to the contours of its jurisdiction under
Article 142 of the Constitution of India, particularly
in the context of the submission that the directions
th
issued vide order dated 7 November, 2025 are
inconsistent with the provisions of the ABC Rules,
2023. It is trite that Article 142 of the Constitution of
India vests this Court with wide and plenary powers
to do “complete justice” in any cause or matter
pending before it, and such power constitutes a
distinct and independent source of jurisdiction, not
circumscribed by the limitations applicable to
ordinary statutory provisions.
51. In Union Carbide Corporation v. Union of
6
India , a Constitution Bench of this Court
underscored the breadth and amplitude of its powers
under Article 142 of the Constitution of India by
6
(1991) 4 SCC 584.
59
holding that the expression “cause or matter” is of the
widest import, encompassing all forms of proceedings
before the Court. It was further observed that
“prohibitions or limitations contained in ordinary laws
cannot, ipso facto, act as prohibitions or limitations on
the constitutional powers under Article 142” , and that
the power under Article 142 is “at an entirely different
level and of a different quality” . At the same time, this
Court clarified that while exercising such power, due
regard must be had to statutory provisions,
particularly those founded on fundamental
considerations of public policy, in assessing what
would constitute “complete justice” in a given case.
For ready reference, the relevant extract from the said
judgment is reproduced hereinbelow: -
“83. It is necessary to set at rest certain
misconceptions in the arguments touching the
scope of the powers of this Court under Article
142(1) of the Constitution. These issues are matters
of serious public importance. The proposition that
a provision in any ordinary law irrespective of
the importance of the public policy on which it
is founded, operates to limit the powers of the
apex Court under Article 142(1) is unsound and
erroneous. In both Garg [1963 Supp 1 SCR 885,
899-900 : AIR 1963 SC 996] as well as Antulay cases
[(1988) 2 SCC 602 : 1988 SCC (Cri) 372] the point
was one of violation of constitutional provisions and
constitutional rights. The observations as to the
60
effect of inconsistency with statutory provisions
were really unnecessary in those cases as the
decisions in the ultimate analysis turned on the
breach of constitutional rights. We agree with Shri
Nariman that the power of the Court under Article
142 insofar as quashing of criminal proceedings are
concerned is not exhausted by Section 320 or 321 or
482 CrPC or all of them put together. The power
under Article 142 is at an entirely different level
and of a different quality. Prohibitions or
limitations or provisions contained in ordinary
laws cannot, ipso facto, act as prohibitions or
limitations on the constitutional powers under
Article 142. Such prohibitions or limitations in
the statutes might embody and reflect the
scheme of a particular law, taking into account
the nature and status of the authority or the
court on which conferment of powers — limited
in some appropriate way — is contemplated. The
limitations may not necessarily reflect or be
based on any fundamental considerations of
public policy. Sri Sorabjee, learned Attorney
General, referring to Garg case [1963 Supp 1 SCR
885, 899-900 : AIR 1963 SC 996], said that
limitation on the powers under Article 142 arising
from “inconsistency with express statutory
provisions of substantive law” must really mean and
be understood as some express prohibition
contained in any substantive statutory law. He
suggested that if the expression ‘prohibition’ is read
in place of ‘provision’ that would perhaps convey the
appropriate idea. But we think that such
prohibition should also be shown to be based on
some underlying fundamental and general issues
of public policy and not merely incidental to a
particular statutory scheme or pattern. It will
again be wholly incorrect to say that powers
under Article 142 are subject to such express
statutory prohibitions. That would convey the
idea that statutory provisions override a
constitutional provision. Perhaps, the proper
61
way of expressing the idea is that in exercising
powers under Article 142 and in assessing the
needs of “complete justice” of a cause or matter,
the apex Court will take note of the express
prohibitions in any substantive statutory
provision based on some fundamental principles
of public policy and regulate the exercise of its
power and discretion accordingly. The
proposition does not relate to the powers of the
Court under Article 142, but only to what is or is
not ‘complete justice’ of a cause or matter and in
the ultimate analysis of the propriety of the
exercise of the power. No question of lack of
jurisdiction or of nullity can arise.”
[Emphasis supplied]
52. The scope and limits of this extraordinary
jurisdiction were further delineated in Supreme
7
Court Bar Association v. Union of India , wherein
a 5-Judge Bench of this Court also considered the
apparent conflict between the principles enunciated
in Union Carbide Corporation (supra) and Prem
Chand Garg (supra) . It was held that there existed,
in fact, no real conflict between the two lines of
authority. While affirming that the powers under
Article 142 of the Constitution of India are plenary
and supplementary in nature, the Court clarified that
they are nonetheless curative and cannot be
exercised in a manner that would “supplant”
7
(1998) 4 SCC 409.
62
substantive law or disregard express statutory
provisions governing the field. This Court
emphasised that although statutory provisions do
not fetter the existence of the power under Article 142
of the Constitution of India, the exercise of such
power must remain consistent with the statutory
framework, save in exceptional circumstances where
the demands of justice so warrant. For ready
reference, the relevant extract from the said
judgment is reproduced hereinbelow: -
“47. The plenary powers of this Court under
Article 142 of the Constitution are inherent in
the Court and are complementary to those
powers which are specifically conferred on the
Court by various statutes though are not limited
by those statutes. These powers also exist
independent of the statutes with a view to do
complete justice between the parties. These
powers are of very wide amplitude and are in the
nature of supplementary powers. This power
exists as a separate and independent basis of
jurisdiction apart from the statutes. It stands
upon the foundation and the basis for its exercise
may be put on a different and perhaps even wider
footing, to prevent injustice in the process of
litigation and to do complete justice between the
parties. This plenary jurisdiction is, thus, the
residual source of power which this Court may
draw upon as necessary whenever it is just and
equitable to do so and in particular to ensure the
observance of the due process of law, to do
complete justice between the parties, while
administering justice according to law. There is
63
no doubt that it is an indispensable adjunct to all
other powers and is free from the restraint of
jurisdiction and operates as a valuable weapon in
the hands of the Court to prevent “clogging or
obstruction of the stream of justice”. It, however,
needs to be remembered that the powers
conferred on the Court by Article 142 being
curative in nature cannot be construed as powers
which authorise the Court to ignore the
substantive rights of a litigant while dealing with
a cause pending before it. This power cannot be
used to “supplant” substantive law applicable to
the case or cause under consideration of the
Court. Article 142, even with the width of its
amplitude, cannot be used to build a new edifice
where none existed earlier, by ignoring express
statutory provisions dealing with a subject and
thereby to achieve something indirectly which
cannot be achieved directly. Punishing a
contemner advocate, while dealing with a contempt
of court case by suspending his licence to practice,
a power otherwise statutorily available only to the
Bar Council of India, on the ground that the
contemner is also an advocate, is, therefore, not
permissible in exercise of the jurisdiction under
Article 142. The construction of Article 142 must be
functionally informed by the salutary purposes of
the article, viz., to do complete justice between the
parties. It cannot be otherwise. As already noticed in
a case of contempt of court, the contemner and the
court cannot be said to be litigating parties.
48. The Supreme Court in exercise of its jurisdiction
under Article 142 has the power to make such order
as is necessary for doing complete justice “between
the parties in any cause or matter pending before it”.
The very nature of the power must lead the Court
to set limits for itself within which to exercise
those powers and ordinarily it cannot disregard a
statutory provision governing a subject, except
perhaps to balance the equities between the
conflicting claims of the litigating parties by
64
“ironing out the creases” in a cause or matter
before it. Indeed this Court is not a court of
restricted jurisdiction of only dispute-settling. It
is well recognised and established that this Court
has always been a law-maker and its role travels
beyond merely dispute-settling. It is a “problem-
solver in the nebulous areas” (see K. Veeraswami
v. Union of India [(1991) 3 SCC 655 : 1991 SCC
(Cri) 734] but the substantive statutory
provisions dealing with the subject-matter of a
given case cannot be altogether ignored by this
Court, while making an order under Article 142.
Indeed, these constitutional powers cannot, in
any way, be controlled by any statutory
provisions but at the same time these powers are
not meant to be exercised when their exercise
may come directly in conflict with what has been
expressly provided for in a statute dealing
expressly with the subject.”
[Emphasis supplied]
53. The contours of the powers under Article 142 of
the Constitution of India were further expounded by
a Constitution Bench of this Court in Shilpa Sailesh
8
v. Varun Sreenivasan , wherein the nature, scope
and limitations of this extraordinary jurisdiction were
comprehensively analysed. This Court observed that
though the power under Article 142(1) of the
Constitution of India is plenary and appears to be
unfettered, it is nonetheless tempered by self-
imposed restraints founded on fundamental
8
(2023) 14 SCC 231.
65
considerations of public policy. It was clarified that
such limitations operate at two levels, namely,
general public policy, encompassing fundamental
constitutional values such as fundamental rights,
secularism and federalism, and specific public policy,
reflected in express and pre-eminent prohibitions
contained in substantive law. The Court further held
that the exercise of power under Article 142 of the
Constitution of India is impermissible only where it
results in an order that is plainly contrary to
substantive statutory provisions rooted in such
fundamental public policy considerations. Drawing
upon the principles laid down in Union Carbide
Corporation (supra) and Supreme Court Bar
Association (supra) , it was reiterated that while this
Court cannot “supplant” substantive law or construct
a new legal regime in disregard of express statutory
provisions, it retains wide discretion to mould relief,
balance equities and address situations where the
law may be silent or inadequate. The power under
Article 142 of the Constitution of India was thus
characterised as a residuary and elastic jurisdiction,
enabling this Court to act as a “problem-solver in the
nebulous areas”, so long as the exercise of such
66
power does not transgress fundamental principles of
general or specific public policy. For ready reference,
the relevant extract from the said judgment is
reproduced hereinbelow: -
“19. Given the aforesaid background and
judgments of this Court, the plenary and
conscientious power conferred on this Court
under Article 142(1) of the Constitution of India,
seemingly unhindered, is tempered or bounded
by restraint, which must be exercised based on
fundamental considerations of general and
specific public policy. Fundamental general
conditions of public policy refer to the
fundamental rights, secularism, federalism, and
other basic features of the Constitution of India.
Specific public policy should be understood as
some express pre-eminent prohibition in any
substantive law, and not stipulations and
requirements to a particular statutory scheme. It
should not contravene a fundamental and non-
derogable principle at the core of the statute.
Even in the strictest sense [ Some jurists have
opined that the judgments on the powers of this
Court under Article 142(1) of the Constitution of
India can be divided into three phases. The first
phase till late 1980s is reflected in the judgments of
Prem Chand Garg v. Excise Commr., 1962 SCC
OnLine SC 10 : AIR 1963 SC 996 and A.R. Antulay
v. R.S. Nayak, (1988) 2 SCC 602 : 1988 SCC (Cri)
372, which inter alia held that the directions should
not be repugnant to and in violation of specific
statutory provision and is limited to deviation from
the rules of procedure. Further, the direction must
not infringe the Fundamental Rights of the
individual, which proposition has never been
doubted and holds good in phase two and three. The
second phase has its foundation in the ratio of
67
the judgment of the eleven-Judge Constitution
Bench of this Court in Golak Nath v. State of
Punjab, 1967 SCC OnLine SC 14 : AIR 1967 SC
1643, dealing with the doctrine of prospective
overruling, which held that Articles 32, 141 and
142 are couched in such wide and elastic terms
as to enable this Court to formulate legal
doctrines to meet the ends of justice, the only
limitation thereon being reason, restraint and
injustice. In Delhi Judicial Service Assn. v. State
of Gujarat, (1991) 4 SCC 406, this Court observes
that any prohibition or restriction contained in
ordinary laws cannot act as a limitation on the
constitutional power of this Court to issue any
order or direction to do “complete justice” in any
“cause” or “matter”. Finally, the moderated
approach has its origin in Union Carbide Corpn.
v. Union of India, (1991) 4 SCC 584, which holds
that this Court, in exercising powers under
Article 142 and in assessing the needs of
“complete justice” of a “cause” or “matter”, will
take note of the express prohibitions in any
substantive statutory provision based on some
fundamental principles of public policy and
regulate the exercise of its power and discretion
accordingly. The judgment of Supreme Court Bar
Assn. v. Union of India, (1998) 4 SCC 409, applies
cautious and balanced approach, to hold that
Article 142 being curative in nature and a
constitutional power cannot be controlled by any
statutory provision, but this power is not meant
to be exercised ignoring the statutory provisions
or directly in conflict with what is expressly
provided in the statute. At the same time, it
observes that this Court will not ordinarily
discard a statutory provision governing the
subject, except perhaps to balance the equities
between the conflicting claims of the parties to
“iron out the creases” in a “cause or matter”
before it. [See Rajat Pradhan, “Ironing out the
Creases : Re-examining the Contours of Invoking
68
Article 142(1) of the Constitution”, (2011) 6 NSLR 1;
Ninad Laud, “Rationalising ‘Complete Justice’ under
Article 142”, (2021) 1 SCC J-30; and Virendra
Kumar, “Notes and Comments : Judicial Legislation
Under Article 142 of the Constitution : A Pragmatic
Prompt for Proper Legislation by Parliament”, (2012)
54 JILI 364]. As observed by us, the ratio as
expounded in Union Carbide Corpn. v. Union of
India, (1991) 4 SCC 584 holds good and applies.],
it was never doubted or debated that this Court
is empowered under Article 142(1) of the
Constitution of India to do “complete justice”
without being bound by the relevant provisions
of procedure, if it is satisfied that the departure
from the said procedure is necessary to do
“complete justice” between the parties. [See Prem
Chand Garg (Prem Chand Garg v. Excise Commr.,
1962 SCC OnLine SC 10 : AIR 1963 SC 996, para
13.]
20. Difference between procedural and substantive
law in jurisprudential terms is contentious, albeit
not necessary to be examined in depth in the present
decision [However, this aspect has been, to some
extent, examined in paras 24 to 37, 56 and 57
herein.], as in terms of the dictum enunciated by
this Court in Union Carbide Corpn. [Union Carbide
Corpn. v. Union of India, (1991) 4 SCC 584] and
Supreme Court Bar Assn. [Supreme Court Bar Assn.
v. Union of India, (1998) 4 SCC 409] , exercise of
power under Article 142(1) of the Constitution of
India to do “complete justice” in a “cause or matter”
is prohibited only when the exercise is to pass an
order which is plainly and expressly barred by
statutory provisions of substantive law based on
fundamental considerations of general or specific
public policy.
21. As explained in Supreme Court Bar Assn.
[Supreme Court Bar Assn. v. Union of India, (1998)
4 SCC 409], the exercise of power under Article
142(1) of the Constitution of India being curative in
nature, this Court would not ordinarily pass an
69
order ignoring or disregarding a statutory provision
governing the subject, except to balance the equities
between conflicting claims of the litigating parties by
ironing out creases in a “cause or matter” before it.
In this sense, this Court is not a forum of restricted
jurisdiction when it decides and settles the dispute
in a “cause or matter”. While this Court cannot
supplant the substantive law by building a new
edifice where none existed earlier, or by ignoring
express substantive statutory law provisions, it
is a problem-solver in the nebulous areas. As long
as “complete justice” required by the “cause or
matter” is achieved without violating
fundamental principles of general or specific
public policy, the exercise of the power and
discretion under Article 142(1) is valid and as per
the Constitution of India. This is the reason why
the power under Article 142(1) of the
Constitution of India is undefined and
uncatalogued, so as to ensure elasticity to mould
relief to suit a given situation. The fact that the
power is conferred only on this Court is an
assurance that it will be used with due restraint
and circumspection. [See DDA v. Skipper
Construction Co. (P) Ltd., (1996) 4 SCC 622.]”
[Emphasis supplied]
54. The decision in Shilpa Sailesh (supra)
therefore affirms that the jurisdiction under Article
142 is both expansive and carefully circumscribed,
expansive in its ability to transcend procedural
limitations and craft appropriate relief, yet
circumscribed by the obligation to remain consistent
with substantive law and constitutional values. It is
this delicate balance between breadth of power and
70
restraint in its exercise that informs the application
of Article 142 of the Constitution of India in the
present case.
55. It must also be noted that the present
proceedings arise out of the exercise of suo moto
jurisdiction by this Court, which is sui generis in
nature and is invoked to address situations having
wide-ranging consequences and adverse effects on
the public at large. Such jurisdiction is exercised not
for the resolution of an inter se dispute between
identifiable parties, but to remedy systemic issues
and to ensure that constitutional guarantees are not
rendered illusory on account of administrative
inaction or regulatory failure. In that sense, the
proceedings transcend the conventional adversarial
framework and assume the character of a public law
action undertaken in furtherance of this Court’s
constitutional duty. The absence of a conventional lis
does not dilute the judicial function, rather, it
enlarges the scope of inquiry, requiring the Court to
consider broader societal implications and long-term
consequences of its directions.
56. The paramount consideration guiding the
exercise of such jurisdiction is the protection and
71
enforcement of the fundamental rights of public at
large, particularly the right to life and safety
guaranteed under Article 21 of the Constitution of
India. Where a situation discloses a continuing or
recurring threat to public safety, health or dignity,
this Court is constitutionally obligated to intervene
and to devise appropriate remedial measures. The
focus, therefore, shifts from adjudication of
individual grievances to the preservation of collective
rights and the prevention of systemic harm. The
exercise of such jurisdiction thus entails a careful
calibration of competing interests, with the
overarching objective of ensuring that systemic
deficiencies are rectified and that threats to public
safety are mitigated in a sustained and meaningful
manner.
57. In the aforesaid backdrop, this Court proceeds
to examine the specific contention advanced on
behalf of the applicants that Rule 11(19) of the ABC
Rules, 2023 must be applied in an absolute and
unqualified manner across all categories of spaces.
This Court is unable to accede to the said submission
for the reasons that follow. While it is true that the
said Rule provides for the re-release of sterilised and
72
vaccinated dogs to the same locality from where they
were picked up, such a provision cannot be read in
isolation or expanded in a manner that would extend
its application to sensitive and restricted premises
such as hospitals, schools, colleges, sports
complexes, transport hubs including airports and
other similar institutional areas. Such an
interpretation would be divorced from the statutory
context and would amount to an impermissible
generalisation of a regulatory provision beyond its
intended scope.
58. As has already been held in the earlier part of
this judgment, a harmonious and purposive
construction of the PCA Act, 1960 and the Rules
framed thereunder, namely, the ABC Rules, 2023,
does not support the continued presence or
compulsory reintroduction of stray dogs within such
institutional spaces. On the contrary, an expansive
application of Rule 11(19) of the ABC Rules, 2023
that contemplates re-release in these areas would be
misconceived, as it would run contrary to the scheme
of the statute and may have serious adverse
consequences on public safety and health. The
material placed on record, as well as the factual
73
backdrop leading to the issuance of the directions,
clearly demonstrate that the presence of stray dogs
in such locations has resulted in grave risks,
particularly to vulnerable sections of society
including children, patients and the elderly.
59. It is also pertinent to note that this Court, while
exercising its jurisdiction, has consistently sought to
strike a careful balance between the statutory
framework governing animal welfare and the
fundamental rights of public at large under Article 21
of the Constitution of India. The directions issued
th
vide order dated 11 August, 2025, which effectively
obviated the principles underlying Rule 11(19) of the
ABC Rules, 2023, were subsequently revisited and
nd
modified by order dated 22 August, 2025, wherein
this Court observed that a blanket direction to pick
up stray dogs from the National Capital Region would
give rise to a ‘catch-22’ situation, inasmuch as such
directions may be incapable of practical compliance,
and accordingly approved the re-release of such dogs
to the same location from where they were picked up.
th
The order dated 7 November, 2025 was thus issued
after due deliberation, with a calibrated approach
aimed at reconciling the competing considerations of
74
animal welfare and human safety, and in exercise of
the powers conferred under Article 142 of the
Constitution of India to restore the balance by
excluding from the operation of re-release those
institutional and public spaces, such as schools,
colleges, hospitals and similar establishments, where
the presence of stray dogs is neither permitted nor
conducive to public safety.
th
60. The directions contained in the order dated 7
November, 2025 were, therefore, intended to operate
within a limited and specific domain, namely, to
safeguard institutional environments from the
hazards posed by the presence of stray dogs, while
continuing to conform to the broader statutory
framework in other contexts. In doing so, this Court
has not supplanted the statutory scheme, rather, it
has merely tailored its application in a manner
consistent with constitutional imperatives and
practical realities, particularly in spaces where the
risk to human life and safety is both immediate and
significant.
61. In the considered view of this Court, no
principle of general or specific public policy, as
understood in the context of Article 142 of the
75
Constitution of India and the jurisprudence
governing its exercise, can be said to mandate or even
contemplate the continued presence of stray dogs
within such institutional areas. The concept of public
policy, whether general or specific, cannot be
construed in a manner that legitimises conditions
which pose a demonstrable and recurring threat to
human life, safety and health, particularly in spaces
frequented by vulnerable sections of society such as
children, patients and the elderly. To hold otherwise
would be to elevate a regulatory provision, intended
for humane control of canine population, to a
position where it overrides fundamental rights and
compromises the safety and well-being of public at
large. Such an interpretation would not only be
contrary to the scheme of the governing statute, but
would also run afoul of the constitutional mandate
under Article 21 of the Constitution of India, which
obligates the State to ensure a safe and secure
environment for all individuals. Public policy,
properly understood, must operate in furtherance of
constitutional values, and cannot be invoked to
justify outcomes that are manifestly opposed to
public safety.
76
62. It is equally necessary to bear in mind that the
power under Article 142 of the Constitution of India
is exercised to bridge gaps where the statutory
framework, though otherwise valid, may not
adequately address emergent or exceptional
situations. The present case discloses precisely such
a situation, where the application of a general
statutory principle, if extended without limitation,
would lead to consequences inconsistent with the
broader objectives of the law and the Constitution.
The directions issued by this Court, therefore, do not
supplant or override the statutory scheme, but rather
modulate and regulate its application in a manner
that is consistent with both legislative intent and
constitutional imperatives. The exercise of power
under Article 142 of the Constitution of India in the
present case, thus, remains well within the
permissible limits as delineated by the precedents
referred supra . It is guided by constitutional values,
informed by the statutory framework, and directed
towards achieving a just and workable balance
between competing interests. Above all, it is anchored
in the overarching requirement of doing complete
justice, ensuring that the protection of human life
77
and safety is not compromised by an unduly
expansive or mechanical application of subordinate
legislation. In the aforesiad view of the matter, the
contention urged on behalf of the applicants seeking
modification, clarification, vacation, recall and/or
th
stay of the directions contained in the order dated 7
November that, notwithstanding the plenary nature
of the power under Article 142 of the Constitution of
India, the same cannot be invoked so as to supplant
substantive law or to issue directions plainly
inconsistent with express statutory provisions
occupying the field, does not merit acceptance in the
facts of the present case, inasmuch as the directions
issued herein neither contravene nor override the
governing statutory framework, but supplement,
clarify and operationalise it in a manner consistent
with its object and purpose.
C. Examination of Ancillary Contentions Raised
on Behalf of the Applicants
63. Upon consideration of the ancillary
submissions advanced on behalf of the applicants,
this Court is of the view that the prayer for
constitution of an expert committee does not merit
th
acceptance. The directions issued vide order dated 7
78
November, 2025 are neither sweeping nor
unstructured, but are calibrated, limited in scope,
and confined to specific categories of institutional
areas such as educational institutions, hospitals,
sports complexes, bus stands/depots (including
Inter-State Bus Terminals) and railway stations.
These are spaces where the presence of stray dogs
has been found to pose a direct and immediate threat
to public safety. The issues sought to be addressed
are neither indeterminate nor incapable of
implementation so as to necessitate the constitution
of an expert body. The existing statutory framework,
coupled with the directions issued by this Court,
provides a sufficiently clear and workable
mechanism, and what is required is effective
implementation rather than further deliberation. The
constitution of an expert committee at this stage
would only delay and deter remedial action in a
matter involving urgent concerns of public safety.
64. The submission regarding the enormity of
financial and infrastructural requirements has, in
the opinion of this Court, been overstated. This Court
is unable to accept the premise that the directions
necessarily entail large-scale acquisition of land or
79
the creation of permanent shelter infrastructure of
the magnitude suggested. The directions do not
mandate the establishment of new and permanent
facilities across the country, but rather contemplate
the utilisation of existing infrastructure, including
gaushalas , cattle pounds, animal shelters and other
such facilities, which may be suitably augmented or
adapted for the purpose. The implementation of the
directions is thus capable of being achieved through
optimisation of existing resources rather than the
creation of an entirely new infrastructure ecosystem.
65. It must also be borne in mind that the
responsibility of managing stray animals is not
confined to the State alone. Animal welfare
organisations, recognised non-governmental
9
organisations , and individuals engaged in animal
care, including those who profess concern for the
welfare of community dogs, can and ought to play a
constructive role in assisting the authorities.
Collaborative efforts between municipal authorities
and such organisations would significantly reduce
the operational burden and facilitate humane and
9
For short, “NGOs”.
80
effective management of stray dogs in accordance
with the statutory framework. The apprehension that
the directions would impose an insurmountable
financial burden on the State does not find favour
with this Court.
66. There has been much clamour on the part of
some NGOs whose learned counsel have tried to
convince the Court that, given the appropriate
opportunities, financial and logistics support, the
NGOs can meaningfully and effectively tackle the
issues of free-ranging dogs in the public areas by
executing the Capture-Sterilise-Vaccinate-Release
(CSVR) model. We have not made any observations
restricting the role of the NGOs in carrying out these
activities. However, contrary to what was stated on
behalf of the NGOs, an argument was advanced that
as a matter of fact, many of the NGOs are indulging
in raising fraudulent bills for procedures that have
never been carried out or in submitting repetitive bills
for procedures previously carried out. This alarming
piece of information has been manifested in a recent
news report which points out that in a particular area
of Madhya Pradesh, the concerned NGO preserved
the private parts of dogs to raise multiple bills for
81
Capture-Sterilise-Vaccinate-Release (CSVR) activities
and attempted to manipulate the procedure for the
10
purpose of monetary gain. The news article referred
to above makes it clear that not all the NGOs are
carrying out these activities for charity and that they
are charging heavily for the procedures undertaken
by them. Hence, we are not inclined to give any
further directions in this regard, leaving it to the
concerned municipal authorities to decide as to
whether the NGOs should be involved in the Capture-
Sterilise-Vaccinate-Release (CSVR) model so as to
alleviate the financial constraints faced by municipal
authorities.
67. However, it is made clear that the concerned
municipal authorities shall be well-advised to
undertake rigorous and comprehensive due
diligence, including detailed background checks,
verification of credentials, assessment of past
performance, technical capability and financial
integrity, before awarding any contracts or tenders to
such NGOs for the implementation of the Capture-
10
MP: 795 dog reproductive organs stockpiled in sterilisation scam;
attempt to pass fake bills; LINK: https://www.aajtak.in/madhya-
pradesh/story/mandla-dog-sterilization-scam-ngo-fake-bill-reproductive-
organs-seized-fir-lcln-rpti-2522850-2026-04-13 .
82
Sterilise-Vaccinate-Release (CSVR) model. The
process of empanelment or engagement shall not be
undertaken in a routine or mechanical manner, but
must be preceded by a careful evaluation of the track
record and credibility of such organisations. Given
that substantial public funds are involved, the
authorities must ensure that the process of
engagement is fair, transparent and in accordance
with established norms. The execution of work by
such NGOs shall be subject to continuous
supervision, periodic inspections, and independent
audits, including financial and performance audits,
so as to ensure fidelity to the sanctioned work. These
safeguards are necessary to prevent misuse,
duplication or diversion of public funds, and to
ensure that the objectives of the Animal Birth Control
programme are not defeated by irregularities or lack
of oversight, but are effectively achieved in a verifiable
and accountable manner.
68. At the same time, this Court cannot lose sight
of the fact that the present situation is, to a
considerable extent, a consequence of the persistent
failure on the part of State authorities and
municipal/local bodies to effectively implement the
83
Animal Birth Control framework. The Animal Birth
Control framework, initially introduced in 2001 and
subsequently strengthened through the amendment
of 2023, has remained largely deficient in its
execution across several jurisdictions. The sporadic,
underfunded and inconsistent implementation of
sterilisation and vaccination programmes has
resulted in an unchecked increase in the stray dog
population and a corresponding rise in incidents of
dog bites and related hazards.
th
69. This Court has, in its order dated 7 November,
th
2025, as well as in the preceding orders dated 11
nd
August, 2025 and 22 August, 2025, has
categorically recorded the lack of effective and
coordinated steps taken by the authorities in
addressing the issue. The material placed on record,
coupled with the factual circumstances noted in the
aforesaid orders, reveals a consistent and continuing
failure on the part of the concerned authorities to
discharge their statutory obligations. Despite the
existence of a well-defined statutory framework, there
has been a conspicuous absence of sustained
administrative effort, institutional accountability,
adequate allocation of resources, and meaningful
84
monitoring mechanisms. The present proceedings
are, therefore, not merely a response to isolated
incidents, but are demonstrative of a deeper and
continuing pattern of systemic administrative lapses
and lethargy extending over a considerable period of
time.
70. The difficulty, therefore, lies not in the absence
or inadequacy of the statutory framework, but in the
failure of its effective and sustained implementation
by the concerned authorities. In this backdrop, the
directions issued by this Court are intended to
catalyze compliance and ensure that the existing
statutory regime is meaningfully enforced in practice.
The authorities concerned are, therefore, required to
discharge their statutory obligations in a diligent,
coordinated and time-bound manner, with clearly
defined responsibilities and enforceable
accountability mechanisms, and to take concrete
steps towards ensuring effective enforcement of the
Animal Birth Control framework, so that the
recurring risks to public safety are addressed in a
structured and sustained manner.
85
D. Accountability and Tortious Liability in the
Context of Stray Dog Management
71. At this stage, it also becomes necessary to
address an important facet which has a direct
bearing on the submissions advanced on behalf of
certain applicants professing concern for the welfare
of stray dogs. While considerable emphasis has been
placed on the protection, feeding and continued
presence of community dogs in public and
institutional spaces, a pertinent question arises as to
whether such individuals, organisations and
associations would be willing to assume
corresponding legal responsibility for the
consequences arising therefrom. In particular,
whether such animal welfare organisations,
associations, or individuals, who claim to care for or
exercise control over stray dogs in a given locality,
would be willing to accept tortious liability in respect
of any injury, harm or damage caused by such dogs
to members of the public. The issue assumes
significance inasmuch as the assertion of a right to
protect or maintain stray dogs in public spaces
cannot be divorced from the obligation to ensure that
such actions do not result in harm to others.
86
72. A similar concern arises in the context of
institutional premises, particularly educational
institutions, where certain animal welfare groups or
student-led bodies are stated to be engaged in the
care and feeding of stray dogs within campuses. In
such situations, the question assumes even greater
significance as to whether such entities/animal
welfare groups would be willing to accept tortious
liability for any incident involving dog bites or attacks
upon students, staff or visitors within the campus.
Institutional spaces, by their very nature, require a
heightened standard of safety, and any activity that
potentially compromises such safety must be
accompanied by a corresponding assumption of
responsibility. The absence of any clear framework
for fixing such liability further underscores the
imbalance between the assertion of rights in favour
of stray animals and the lack of accountability for the
consequences of their presence in sensitive
environments. This aspect, in the considered view of
this Court, merits serious consideration in the overall
approach towards managing the issue of stray dogs
in public and institutional spaces.
87
73. It must be noted that fervent arguments were
raised on behalf of the National Academy of Legal
Studies and Research, University of Law,
11
Hyderabad that it has institutionalised humane
treatment of stray dogs in its campus by creating an
Animal Law Centre and that all stakeholders
including the students, staff, etc. are being sensitised
towards the dogs present in the campus. It was
submitted that similar social experiments could be
undertaken in other educational institutions which
would act in furtherance of the spirit of the ABC
Rules, 2023, emphasise the inculcation of empathy
among students and inspire them to be kind to the
animals in both letter and spirit of the statutory
regime. In this regard, we may simply observe that,
in case the Animal Law Centre wishes to carry out
the work in terms of the Capture-Sterilise-Vaccinate-
Release (CSVR) model inside the campus of NALSAR
University of Law, Hyderabad, such activity can be
permitted on an experimental basis, subject to the
pre-condition that the Animal Law Centre shall
furnish an undertaking to the Vice Chancellor of the
11
Fort short, “NALSAR University of Law, Hyderabad”.
88
NALSAR University of Law, Hyderabad, that, in the
event of any incident of stray dog bite occurring
within the campus, the Animal Law Centre shall be
liable to face tortious liability for the injury caused to
the individual/s concerned.
74. This Court is of the considered opinion that any
framework concerning the management and
protection of stray dogs must necessarily be
accompanied by clearly defined principles of
accountability. The assertion of rights or interests in
favour of such animals cannot operate in isolation,
divorced from the corresponding responsibility to
safeguard human life and safety. Insofar as the
animal welfare groups or student-led bodies in
educational institutions are concerned, it shall be
mandatory for any such group or body operating
within such campuses to expressly undertake such
liability by filing an affidavit to this effect with the
Head of the Institution concerned, failing which no
such activity of maintaining or feeding stray dogs
shall be permitted within the institutional premises.
Failure to comply would entail suitable action against
the Head of the Institution concerned.
89
4. Conclusion: -
75. As an upshot of the aforesaid discussion, this
Court holds that the statutory scheme under the PCA
Act, 1960 and the ABC Rules, 2023 does not
mandate, nor can it be interpreted to require or
justify the continued presence or re-release of stray
dogs within institutional premises or other restricted-
access areas. Consequently, such dog population
cannot be held to fall within the scope of Rule 7(2)
read with Rule 11(19) of the ABC Rules, 2023. The
th
directions issued vide order dated 7 November,
2025, excluding such premises from the operation of
re-release, are in consonance with a purposive and
harmonious interpretation of the statutory
framework and fall within the permissible exercise of
this Court’s powers under Article 142 of the
Constitution of India, being guided by constitutional
values and the imperative of ensuring public safety.
76. In view of the above, the submissions advanced
on behalf of the applicants seeking modification,
clarification, vacation, recall and/or stay of the
th
directions contained in the order dated 7 November,
2025, particularly those pertaining to the removal of
stray dogs from institutional areas and the
90
prohibition on their re-release at the same locations,
are found to be devoid of merit. Accordingly, all
interlocutory applications seeking modification,
clarification, vacation, recall and/or stay of the
aforesaid directions stand dismissed.
III. PART II: Consideration of Interlocutory
Applications Challenging the Standard Operating
Procedure Issued by the Animal Welfare Board of
India in Compliance of Direction (J) Contained in
th
Order Dated 7 November, 2025
77. At the outset, it is required to be noted that the
12
Animal Welfare Board of India , in compliance with
Direction (J) issued by this Court vide order dated
th
7 November, 2025, proceeded to formulate and
13 th
publish Standard Operating Procedures dated 27
November, 2025 governing the prevention of dog bites
and management of stray dogs in institutional
premises. The said SOPs were intended to provide a
uniform framework to be adopted across all States
and Union Territories for effective implementation of
the directions issued by this Court. The issuance of
such SOPs was in furtherance of the mandate cast by
12
For short, “AWBI”.
13
For short, “SOPs”.
91
this Court to ensure a coordinated, structured and
time-bound response by all concerned authorities in
addressing the issue of stray dog management,
particularly in sensitive public spaces. The SOPs,
thus, broadly seek to translate the directions of this
Court into operational guidelines capable of uniform
application, while also delineating the roles and
responsibilities of municipal authorities, institutional
managements and other stakeholders involved in the
process.
78. The SOPs, in essence, lay down a
comprehensive operational framework addressing
multiple facets of stray dog management, including
identification and establishment of shelters,
regulation of shelter capacity in accordance with
prescribed spatial parameters, feeding protocols,
waste management systems, and deployment of
adequate personnel for maintenance and
supervision. They further mandate the identification
of institutional areas such as educational
institutions, hospitals (including district hospitals,
primary health centres and medical colleges), sports
complexes or stadia, bus stands/depots and railway
stations, and also extend to other public spaces
92
including religious places, children’s parks, airports,
helipads, seaports, tourist sites and recreational
areas. The SOPs require the securing of such
premises through fencing and other infrastructural
measures to prevent ingress of stray dogs, the
appointment of nodal officers for supervision, and the
coordinated removal of stray dogs from such areas,
followed by their sterilisation, vaccination and
relocation to designated shelters. They also
contemplate the involvement of animal welfare
organisations, establishment of community kennels,
and mobilisation of financial and logistical resources.
Additionally, the SOPs emphasise public awareness
measures, responsible waste disposal practices,
structured feeding protocols, and periodic monitoring
and reporting mechanisms to ensure effective
implementation across jurisdictions.
79. Subsequent thereto, multiple interlocutory
applications came to be filed assailing the validity of
the aforesaid SOPs on diverse grounds. Learned
counsel appearing for the applicants contended that
the SOPs are ultra vires the directions issued by this
Court and travel beyond the scope of the order dated
th
7 November, 2025. It was urged that while this
93
Court had confined its directions to specific
institutional areas such as educational institutions,
hospitals, sports complexes, bus stands/depots and
railway stations, the SOPs issued by the AWBI
impermissibly expands their applicability to a wider
category of public spaces including religious places,
parks, tourist sites and recreational areas. According
to the applicants, such expansion amounts to an
unwarranted assumption of jurisdiction by the AWBI
and is liable to be struck down.
80. It was further contended that the SOPs are
contrary to the statutory framework under the PCA
Act, 1960 and the ABC Rules, 2023, inasmuch as it
envisages large-scale removal and permanent
sheltering of stray dogs, thereby departing from the
Capture-Sterilise-Vaccinate-Release (CSVR) model
contemplated under the ABC Rules, 2023. Learned
counsel submitted that the shelter-based model
prescribed under the SOPs is not only legally
unsustainable but also scientifically flawed and
violative of internationally recognised animal welfare
standards, particularly with respect to group housing
and spatial requirements. It was also urged that the
SOPs fail to incorporate necessary safeguards such
94
as behavioural assessment, veterinary supervision
and appropriate grouping criteria, thereby rendering
them arbitrary and detrimental to animal welfare.
81. It was additionally submitted that the SOPs
have been formulated without adequate stakeholder
consultation or consideration of ground-level
realities, thereby resulting in a framework that is
both impractical and incapable of effective
implementation. Learned counsel emphasised that
the logistical and financial implications of
establishing large-scale shelter infrastructure, as
contemplated under the SOPs, have not been duly
assessed, and that the burden of implementation
would disproportionately fall upon already resource-
constrained municipal authorities. It was, thus,
urged that the SOPs, in their present form, are liable
to be set aside or suitably modified to align with the
statutory scheme, scientific principles and practical
feasibility.
82. Having considered the aforesaid submissions,
this Court is unable to accede to the challenge laid to
th
the SOPs. A careful reading of the order dated 7
November, 2025 makes it abundantly clear that while
this Court had, illustratively, referred to certain
95
categories of institutional areas such as educational
institutions, hospitals, sports complexes, bus
stands/depots (including Inter-State Bus Terminals)
and railway stations, the said enumeration was not
intended to be exhaustive or restrictive in nature. The
directions were issued in the context of addressing
serious concerns relating to public safety in sensitive
and high-footfall areas, and the examples furnished
therein were merely illustrative of the nature of
spaces where such concerns arise. The emphasis of
this Court was not on the nomenclature of the public
spaces, but on their functional character, namely,
areas which witness substantial public movement,
congregation and vulnerability, thereby necessitating
heightened safeguards against risks posed by the
presence of stray dogs. It would, therefore, be
contrary to the very object of the directions to
construe them in a restricted or pedantic manner so
as to confine their applicability only to the specific
categories expressly mentioned, to the exclusion of
other similarly situated public spaces exhibiting
comparable characteristics.
83. In that view of the matter, the inclusion of
additional categories of public places such as
96
religious sites, parks, tourist locations and other
similar areas in the SOPs cannot be said to be beyond
the scope of the directions issued by this Court. On
the contrary, such places are equally characterised
by significant public access and congregation, often
involving continuous and dense footfall, including by
vulnerable sections such as children, elderly persons
and tourists unfamiliar with local conditions, and
therefore stand on a similar footing as the
institutional areas expressly referred to in the order
th
dated 7 November, 2025. The nature and use of
such spaces, coupled with the attendant risks to
public safety, bring them squarely within the broader
concerns that weighed with this Court while issuing
the said directions. The extension of the SOPs to such
analogous spaces is thus in furtherance of the object
underlying the directions issued by this Court,
namely, the protection of public safety and
prevention of dog-bite incidents in areas frequented
by the general public, and ensures that the remedial
framework is not rendered ineffective by an unduly
narrow or compartmentalised application limited
only to specifically enumerated categories.
97
84. In the preceding part of this judgment, this
Court has already held that stray dogs do not possess
an indefeasible right to be re-released to the same
location from where they were picked up, and their
presence in sensitive or restricted-access public
spaces cannot be justified by invoking Rule 7(2) read
with Rule 11(19) of the ABC Rules, 2023. The said
provisions, when construed in their proper statutory
context, do not confer any absolute or unqualified
entitlement of re-release, irrespective of the nature of
the premises or overriding considerations of public
safety. Once it is held that such provisions do not
mandate the continued presence or reintroduction of
stray dogs in such areas, the challenge to the SOPs
on the ground that it departs from the principle of re-
release must necessarily fail. The argument founded
upon an alleged inconsistency with the statutory
scheme thus stands completely obliterated in view of
the interpretation already placed by this Court on the
relevant provisions. The SOPs issued by the AWBI, in
substance, seek to operationalise the directions
issued by this Court in a structured and
implementable manner, and cannot be said to
transgress either the statutory framework or
98
constitutional principles, but rather constitute an
administrative mechanism to give effect to the
mandate of this Court in a uniform and effective
manner across jurisdictions.
85.
In view of the foregoing discussion, this Court
finds no reason whatsoever to interfere with the
th
Standard Operating Procedures dated 27
November, 2025 issued by the Animal Welfare Board
of India in compliance with the directions of this
Court. The challenge laid to the SOPs, both on the
ground of alleged excess of jurisdiction as well as on
the basis of inconsistency with the statutory scheme,
does not merit acceptance in light of the conclusions
recorded hereinabove. Accordingly, all interlocutory
applications challenging the validity of the said SOPs
stand dismissed.
IV. PART III: Status of Compliance by the States
and Union Territories with the Directions
Issued by this Court
86. A perusal of the record indicates that the States,
Union Territories, the National Highways Authority of
14
India and the Union of India have filed their
14
For short, “NHAI”.
99
respective affidavits in compliance with the directions
th
issued by this Court vide order dated 7 November,
2025. The learned Amicus Curiae , Shri Gaurav
Agrawal and his associates have made painstaking
and commendable efforts in placing before this Court
a comprehensive summary report delineating the
status of compliance across the States and Union
Territories.
87. A bare examination of the compliance affidavits
reveals a pervasive and deeply concerning pattern
across several States and Union Territories, namely,
the glaring inadequacy of infrastructural capacity to
effectively respond to a situation of such
unprecedented magnitude. It has been brought to the
notice of this Court that the number of Animal Birth
Control (ABC) centres is grossly insufficient, and even
where such centres exist, they are frequently
constrained by a lack of trained personnel, veterinary
expertise, equipment and logistical support. In
several instances, the facilities are operating far
below their intended capacity, thereby severely
limiting their ability to undertake sterilisation and
vaccination drives in a sustained and systematic
manner.
100
88. The cumulative effect of these deficiencies is
that the existing institutional framework remains
wholly ill-equipped to deal with the scale, complexity
and urgency of the problem relating to the growing
population of stray dogs and the attendant risks to
public safety and health. The material on record,
thus, clearly indicates that, in its present form, the
infrastructure across States and Union Territories is
neither commensurate with the magnitude of the
issue nor capable of ensuring effective
implementation of the statutory and judicial
mandates governing the field.
89. This Court cannot lose sight of the fact that the
Animal Birth Control framework was first introduced
as early as in the year 2001, and was subsequently
revised and strengthened by the ABC Rules, 2023.
Despite the passage of more than two decades, there
has been a discernible absence of sustained,
systematic and incremental efforts on the part of the
States and Union Territories to expand and fortify the
requisite infrastructure in proportion to the steadily
increasing population of stray dogs. The material
placed on record reveals that the implementation of
the Animal Birth Control framework has, in large
101
measure, remained sporadic, under-funded and
uneven across jurisdictions, lacking both continuity
and institutional depth. In several regions,
sterilisation and vaccination programmes have been
undertaken in a fragmented manner, without
adequate planning, monitoring or follow-through,
thereby significantly undermining their efficacy.
Such an approach not only falls short of the statutory
mandate but also defeats the very object sought to be
achieved by the framework, which envisages a long-
term, coordinated and scientifically driven
mechanism for population control and mitigation of
public health risks.
90. Had the States and Union Territories acted with
due diligence and foresight in implementing the
mandate of the Animal Birth Control framework from
its inception, including the timely and phased
augmentation of sterilisation capacity, sustained
vaccination drives and the development of adequate
institutional infrastructure, the present situation
would not have assumed such alarming proportions.
The framework envisaged under the ABC Rules, 2023
was intended to operate as a preventive and long-
102
term mechanism, which required continuous and
coordinated effort over time.
91. The failure to adopt such a proactive, structured
and sustained approach has, therefore, resulted in a
largely reactive and crisis-driven response,
necessitated by the escalation of the problem rather
than its prevention. Such an approach is neither
efficient nor capable of yielding durable solutions,
particularly in a matter involving public health,
human safety and ecological balance. This Court is,
therefore, constrained to observe that the prolonged
inaction, coupled with the absence of institutional
commitment to the effective implementation of the
Animal Birth Control framework, has contributed
significantly to the persistence as well as the
aggravation of the problem, which has now assumed
dimensions warranting urgent and systemic
intervention.
92. After reserving judgment in the present matter,
this Court has been apprised of multiple reports
indicating that incidents of dog bites and stray dog
attacks continue to occur across different parts of the
country with alarming frequency and severity. The
reports brought to the notice of this Court reveal that
103
the magnitude of the problem and the resultant
threat posed to public safety has assumed deeply
disturbing proportions. The incidents disclosed are
not isolated or sporadic occurrences, but reflect a
continuing and widespread pattern of attacks
resulting in severe physical injury, psychological
trauma and, in several cases, loss of human life. It is
clear that the unchecked population of dogs has
become increasingly feral, and such animals have no
place in areas densely populated by human beings
owing to the serious threat they pose to public safety.
93. A newspaper report from Rajasthan brought to
the notice of this Court highlights that in the city of
Sri Ganganagar alone, as many as 1840 dog-bite
incidents were reported within a span of merely three
months, while in Sikar, several incidents involving
attacks on children by stray dogs have been reported
during the same period. In Udaipur, approximately
1750 cases of dog bites have reportedly been recorded
in the year 2026 till the date of publication of the
report, whereas Bhilwara witnessed 42 persons being
bitten by stray dogs in a single day. The report further
refers to deeply disturbing incidents in which young
104
children suffered grievous injuries, including
mauling of the face and limbs by stray dogs.
94. The situation prevailing in other States is even
more alarming. It has been brought to the notice of
this Court that the State of Tamil Nadu alone
recorded approximately 2.63 lakh dog-bite cases
within the first four months of the year 2026, along
with 17 reported deaths attributable to such
incidents. It has been reported that nearly 62,000
dog-bite cases were recorded in each of the months
of January and February, 71,000 cases in March,
and approximately 68,000 cases in April, 2026,
thereby constituting a substantial proportion of the
total 6.25 lakh dog-bite cases and 34 deaths recorded
15
during the entirety of the previous year.
95. This Court has also been apprised of further
reports published in leading national newspapers
which demonstrate that the menace of stray dog
attacks has extended to public spaces of critical
importance, including airports, residential areas and
urban centres across multiple States. A report
15
In just four months of 2026, Tamil Nadu records 2.63 lakh dog bites,
17 deaths; LINK: https://www.thehindu.com/news/national/tamil-
nadu/in-four-months-tamil-nadu-records-263-lakh-dog-bites-17-
deaths/article70947531.ece .
105
concerning the Indira Gandhi International Airport,
New Delhi, states that airport authorities themselves
acknowledged that at least 31 dog-bite incidents had
st
been reported across the airport terminals since 1
16
January, 2026. The report further records
allegations of aggressive stray dogs within airport
premises and the consequent attempts by authorities
to remove or relocate such animals after incidents
th st
involving passengers being bitten on 30 and 31
March, 2026. The very occurrence of repeated dog-
bite incidents within one of the country’s busiest
international airports demonstrates the grave
inadequacy of existing containment and public safety
measures.
96. Another report relating to the State of
Karnataka records that more than 2 lakh dog-bite
cases were reported within merely the first four
months of the year 2026, accompanied by at least 25
17
rabies-related deaths during the same period. The
16
Airport cites 31 bite cases, attempted relocation for action on stray
dogs; LINK:
https://www.newindianexpress.com/states/delhi/2026/Apr/05/airport-
cites-31-bite-cases-attempted-relocation-for-action-on-stray-dogs .
17
Health department on high alert as Karnataka records over 2 lakh
dog bite cases, 25 deaths in four months; LINK:
https://www.news9live.com/city/bengaluru/health-department-on-
high-alert-as-karnataka-records-over-2-lakh-dog-bite-cases-25-deaths-
in-four-months-2968920 .
106
report notes that Vijayapura district alone recorded
approximately 13,997 cases, while the Greater
Bengaluru Authority region reported more than
13,400 cases involving both stray and pet dogs.
Bengaluru Urban district was stated to have recorded
the highest number of rabies-related deaths with six
fatalities. The report further indicates a steep and
continuing rise in dog-bite incidents in the State over
the preceding years, with the number of cases
increasing from approximately 2.3 lakhs in 2023 to
nearly 5 lakhs in 2025. Such figures reveal that the
issue has acquired the dimensions of a serious public
health and law and order concern affecting millions
of citizens.
97. This Court has additionally been informed of
alarming incidents reported from the city of Surat in
the State of Gujarat, including a widely reported
occurrence involving a foreign national, namely a
German traveler, who was allegedly attacked and
18
bitten by stray dogs while visiting the city. Reports
concerning Surat further indicate a substantial rise
18
German man praises India's healthcare after getting free treatment
for dog bite; LINK: https://www.indiatoday.in/trending-
news/story/german-man-praises-indias-healthcare-after-getting-free-
treatment-for-dog-bite-in-gujarat-2894660-2026-04-11 .
107
in dog-bite incidents over recent years, causing
increasing concern amongst residents and local
authorities alike. Such incidents not only endanger
the safety and dignity of citizens and visitors but also
adversely affect public confidence in civic
administration and urban governance.
98. The aforesaid figures, viewed cumulatively,
reveal the staggering dimensions of the problem and
underscore the pressing necessity for immediate,
sustained and effective intervention. The harm
caused by such incidents is not merely statistical in
nature, but has grave human, societal and public
health consequences, the extent whereof is both
enormous and, in many cases, unfathomable. This
Court is constrained to observe that, notwithstanding
the directions issued by this Court vide orders dated
nd th
22 August, 2025 and 7 November, 2025, as well
as the statutory framework operating in the field, the
material placed on record and the subsequent reports
brought to the notice of this Court indicate that the
intended effect of the directions has yet not
adequately percolated to the ground level. The
continued occurrence of such incidents reflects
serious deficiencies in implementation and
108
enforcement on the part of the concerned authorities.
This Court, therefore, makes it clear that any
continued non-compliance or apathy in the
implementation of the directions issued by this Court
and hereinafter, by the jurisdictional High Courts
shall be viewed seriously, and the erring officials of
the municipal authorities and the concerned
departments of the States and Union Territories shall
render themselves liable for appropriate proceedings,
including proceedings for contempt of Court,
disciplinary proceedings and tortious liability.
99. In this backdrop, it must be emphatically
reiterated that the States and Union Territories are
under a continuing and untrammeled constitutional
obligation to ensure the protection of the
fundamental right to life and safety of citizens under
Article 21 of the Constitution of India. This obligation
is not merely passive in nature but casts an
affirmative duty upon the States and Union
Territories to take all necessary and effective
measures to prevent conditions that pose a threat to
public safety, health and well-being. Such obligation
necessarily extends to the creation, augmentation
and sustained maintenance of adequate
109
infrastructure for the effective implementation of the
Animal Birth Control framework, including
sterilisation, vaccination, sheltering and overall
scientific management of stray dogs. The right to live
with dignity under Article 21 of the Constitution of
India necessarily encompasses the right of every
citizen to move freely and access public spaces
without living under a constant apprehension of
physical harm, attack or exposure to life-threatening
events such as dog bites in public areas. The State
cannot remain a passive spectator where preventable
threats to human life continue to proliferate in the
face of statutory mechanisms specifically designed to
address them.
100. The responsibility of the States and Union
Territories, in this regard, cannot be diluted or
deferred on the ground of administrative
inconvenience, financial constraints or logistical
challenges. These are matters that fall squarely
within the domain of governance and prioritisation,
and cannot be permitted to operate as constitutional
alibis for executive paralysis in matters directly
implicating human life and public safety. The
constitutional mandate under Article 21 of the
110
Constitution of India obligates the State to act with
due diligence, foresight and urgency, and to ensure
that statutory frameworks such as the Animal Birth
Control framework are implemented in a manner that
is both effective and responsive to ground realities.
Financial limitations or logistical inconvenience can
never furnish a valid defence where the continued
failure of the State results in avoidable injury, trauma
and loss of human life.
101. This Court must also emphatically observe that
while considerations pertaining to animal welfare and
the protection of sentient beings constitute matters
of undeniable constitutional, statutory and moral
significance, such considerations cannot be
permitted to eclipse or subordinate the paramount
obligation of the State to safeguard human life, bodily
integrity and public safety. When the safety and lives
of human beings are weighed against the interests
and welfare of sentient beings, the constitutional
balance must necessarily and unequivocally tilt in
favour of the preservation and protection of human
life. The right guaranteed under Article 21 of the
Constitution of India stands at the highest pedestal
of constitutional protection, and casts upon the State
111
an affirmative, non-negotiable and continuing duty to
take all expedient, effective, preventive and legally
permissible measures necessary to secure citizens
against threats to life and safety arising from stray
dog attacks and related dangers. Any failure,
hesitation or administrative apathy in adopting such
measures would strike at the very core of the
constitutional guarantee under Article 21 and would
render the fundamental rights guaranteed to citizens
illusory, hollow and incapable of meaningful
enforcement in the lived realities of society.
Compassion for animal life, howsoever important,
cannot be interpreted in a manner that compels
citizens to endure recurring threats to their own lives,
safety and bodily integrity.
102. The States and Union Territories cannot,
therefore, plead helplessness in the face of an
emergent situation of this nature. Governance, in its
true sense, demands anticipatory planning, timely
execution and sustained adherence to statutory
mandates, particularly in matters bearing upon
public health and safety. The continued inadequacy
of infrastructure, despite the existence of a well-
defined legal framework, reflects a systemic lack of
112
institutional prioritisation and administrative will,
which cannot be countenanced any further. It is
incumbent upon the authorities concerned to
recognise that issues of this magnitude require
proactive, coordinated and time-bound interventions,
and not ad hoc or reactive measures. The failure to
do so not only undermine the efficacy of the statutory
regime but also erodes the ability of the State to
discharge its constitutional obligations.
103. This Court must also observe that the repeated
incidents continuing to surface even after the
issuance of directions by this Court which
demonstrates that the administrative machinery
tasked with implementation at the field level has
remained grossly inadequate and, in several cases,
lacking in seriousness and accountability. The
continued recurrence of such incidents despite
repeated judicial intervention reflects a disturbing
degree of administrative inertia which this Court
cannot permit to persist any further. Where State
authorities fail to discharge their constitutional and
statutory obligations despite repeated warnings and
directions, constitutional courts would be fully
113
justified in adopting stricter supervisory and coercive
measures to secure compliance.
104. This Court cannot also remain oblivious to the
harsh and deeply disturbing ground realities
emerging from various parts of the country, where
young children have been mauled, elderly persons
have been attacked, ordinary citizens have been left
vulnerable in public spaces and even international
travellers have fallen victim to such incidents. If such
conditions are permitted to continue unchecked, the
inevitable consequence may lead to a regression
towards a state where the Darwinian theory of
evolution, namely, the survival of the fittest would
effectively govern civic life and public spaces. Such a
situation would be wholly incompatible with a
constitutional democracy governed by the rule of law.
The Constitution of India does not envisage a society
where children, elderly persons and vulnerable
citizens are compelled to survive at the mercy of
physical strength, chance or circumstance owing to
the failure of the State machinery to discharge its
constitutional and statutory obligations. The
fundamental guarantee under Article 21 of the
Constitution of India exists precisely to ensure that
114
the weak and vulnerable are afforded equal
protection of life, safety and dignity under the
constitutional order.
105. It is further necessary to observe that the
responsibility of ensuring compliance with the
directions issued by this Court must cascade across
all levels of administration, from the State
Governments down to municipal authorities,
Panchayati Raj institutions and local bodies.
Effective implementation would require coordinated
action, regular monitoring, inter-departmental
convergence and clearly defined lines of
accountability. The role of supervisory authorities,
including District Magistrates and senior
administrative officials, assumes particular
significance in ensuring that the directions are not
reduced to mere formality but are implemented in
their true spirit.
106. In the course of the present proceedings, this
Court has also considered the compliance affidavit
filed by NHAI. A perusal thereof indicates that NHAI
has taken the position that it is substantially
dependent upon the respective State Governments
and Union Territories for the removal of stray cattle
115
and other animals from National Highways and
National Expressways, and that such functions are
ordinarily discharged through the local
administrative and municipal machinery, with NHAI
assuming a limited role of coordination and
facilitation.
107. This Court is unable to accept such a position
in its entirety. The NHAI, being a statutory authority
entrusted with the development, maintenance and
management of National Highways and National
Expressways, cannot absolve itself of its crucial
responsibility of maintaining road safety by placing
exclusive reliance upon the States and Union
Territories. The obligation to ensure safe, efficient
and obstruction-free highways necessarily
encompasses the duty to address hazards arising
from the presence of stray cattle and other animals.
The NHAI possesses the requisite administrative,
financial and logistical wherewithal to respond
effectively to such situations, including by deploying
dedicated transport mechanisms, creating necessary
holding or shelter infrastructure, and entering into
structured arrangements with animal welfare
organisations, gaushalas and other competent
116
agencies for the safe handling and relocation of such
animals. The discharge of this responsibility must,
therefore, be proactive, coordinated and
institutionally owned, and cannot be relegated
entirely to State or local authorities, particularly in
matters directly impinging upon public safety on
National Highways and National Expressways.
108. In view of the aforesaid, this Court deems it
appropriate to issue the following directions: -
A. The States and Union Territories shall forthwith
take decisive, coordinated and time-bound
steps for enhancing and augmenting the
infrastructure necessary for effective
implementation of the Animal Birth Control
framework, including the expansion of
sterilisation and vaccination capacity,
strengthening of existing facilities, and creation
of additional institutional mechanisms
commensurate with the scale and urgency of
the issue.
B. The States and Union Territories shall ensure
the establishment of at least one fully functional
Animal Birth Control Centre in each district,
duly equipped with requisite veterinary
117
infrastructure, trained personnel, surgical
facilities and supporting logistics, so as to
enable the systematic, continuous and large-
scale implementation of sterilisation and
vaccination programmes. Such centres shall be
made operational in a time-bound manner and
shall function with adequate capacity to
address the local population of stray dogs, with
proper record-keeping, monitoring and periodic
reporting to ensure effective and sustained
implementation of the Animal Birth Control
framework. It is further directed that, having
regard to the population density and territorial
extent of each district, the concerned
departments of the States and Union Territories
shall take an appropriate decision with respect
to the expansion of the number of Animal Birth
Control Centres, wherever necessary, so as to
ensure effective coverage and implementation of
the Animal Birth Control framework.
C. The concerned departments/authorities of the
States and Union Territories shall take all
necessary measures to implement the
directions issued by this Court, and shall
118
ensure that the same are carried out in letter as
well as in spirit, without any delay or dilution,
and shall also strictly comply with the Standard
Operating Procedures issued by the Animal
Welfare Board of India in this regard.
D. The concerned departments/authorities of the
States and Union Territories, as well as the
Union of India (in respect of public
areas/spaces falling within its jurisdiction),
shall take an informed and reasoned decision
regarding the extension of the directions issued
by this Court to other public spaces
characterised by high footfall and public utility,
including but not limited to places of public
congregation and transit, having due regard to
the necessity of ensuring a safe and secure
environment for public at large. Such decision
shall be taken upon a careful assessment of
ground realities, risk to public safety, and the
functional nature of such spaces, and shall be
implemented in a time-bound and coordinated
manner so as to ensure uniformity and
effectiveness in enforcement.
119
E. The States and Union Territories shall
undertake comprehensive capacity-building
measures, including training of personnel,
augmentation of veterinary services,
strengthening of vaccination drives and creation
of adequate shelter facilities, in coordination
with relevant departments and agencies.
F. The States and Union Territories shall also
ensure adequate availability of anti-rabies
vaccines and immunoglobulin in all
Government medical facilities, and shall put in
place effective public health response
mechanisms to deal with cases of dog bites.
G. The NHAI shall, in coordination with the
concerned States and Union Territories,
formulate and implement a comprehensive and
time-bound mechanism for addressing the
presence of stray cattle and other animals on
National Highways and National Expressways,
including the deployment of specialised
transport vehicles for the safe handling and
relocation of stray cattle and other animals, and
the creation or earmarking of appropriate
holding and shelter facilities, and entering into
120
appropriate arrangements with animal welfare
organisations, gaushalas , and other competent
agencies for their safe handling and relocation.
The NHAI shall also establish an effective
monitoring and coordination framework to
ensure continuous oversight and prompt
response in such matters.
H. In areas where the population of stray dogs has
assumed alarming proportions and where
incidents of dog bites or aggressive attacks have
become frequent and pose a continuing threat
to public safety, the concerned authorities may,
subject to due assessment by qualified
veterinary experts and strictly in accordance
with the provisions of the Prevention of Cruelty
to Animals Act, 1960, the Animal Birth Control
Rules, 2023 and other applicable statutory
protocols, take such measures as may be legally
permissible, including euthanasia in cases
involving rabid, incurably ill or demonstrably
dangerous/aggressive dogs, so as to effectively
curb the threat posed to human life and safety.
I. It is made emphatically clear that the officers
and officials of the municipal authorities,
121
Panchayati Raj institutions, local bodies and
the concerned departments of the States and
Union Territories, autonomous
bodies/institutions and the persons in-charge
of all other institutions, i.e., schools, colleges,
hospitals, etc., who are entrusted with the
implementation of the directions issued by this
Court, shall be entitled to due protection for
acts performed by them in good faith and in
bona fide discharge of their official duties and
compliances carried out pursuant to the
present order and the earlier orders passed by
this Court in the present proceedings.
Accordingly, no First Information Report,
criminal complaint or coercive proceedings shall
ordinarily be initiated against such officers or
officials in respect of actions
bona fide
undertaken for the purpose of implementing the
directions issued by this Court, save and except
where a case of , gross
prima facie mala fides
abuse of authority or actions wholly dehors the
directions issued by this Court is made out. If
necessary, the High Court in of the
seisin
continuing mandamus in terms of the present
122
order shall be at liberty to pass appropriate
orders to prevent frivolous, vexatious or
malicious proceedings against such officers or
officials.
109. The concerned authorities of the States and
Union Territories, the National Highways Authority of
India, as well as the Union of India shall ensure strict
and faithful compliance with the directions issued by
nd
this Court vide orders dated 22 August, 2025 and
th
7 November, 2025, in addition to the directions
contained in the present order, and shall take all
necessary measures to ensure that the same are
implemented effectively, in a coordinated and time-
bound manner, without any deviation or dilution.
110. Having dealt with all the applications and
having delineated the measures requiring
compliance, what now remains for consideration is
whether the task of monitoring and ensuring
compliance with the directions issued by this Court
ought to be retained by this Court, or whether the
same can be more appropriately entrusted to the
jurisdictional High Courts. In this context, and in
view of the nature, extent, expanse, outreach and
123
complexity of the directions issued herein, and
bearing in mind that their effective implementation
primarily lies within the domain of local municipal
bodies, panchayats and district administrations, this
Court is of the considered opinion that decentralised
continuous judicial oversight would be far more
efficacious than exclusive centralised monitoring.
The issues arising in the present proceedings are
inherently fact-specific, regionally nuanced and
require sustained supervision at the grassroots level,
which can be more appropriately undertaken by the
jurisdictional High Courts in exercise of their
constitutional jurisdiction.
111. A pan-India monitoring exercise by this Court,
in respect of day-to-day compliance, would not only
be administratively burdensome and time-intensive,
but may also not achieve the degree of
responsiveness and efficacy that the situation
demands. On the other hand, entrusting the High
Courts with the responsibility of monitoring would
ensure closer engagement with local conditions,
timely corrective intervention and more effective
enforcement of the directions issued, while also
enabling the formulation of context-sensitive
124
measures suited to the peculiar needs of each State
and region. In this backdrop, and with a view to
securing effective, continuous and result-oriented
implementation of the orders passed by this Court,
the following directions are given: -
A. For the purpose of ongoing compliance and
monitoring, all High Courts are directed to
register a suo moto writ petition, in the name
and style of: “In Re: Compliance with the
directions issued by the Supreme Court in
Suo Motu Writ Petition (Civil) No(s). 5 of
2025” , as a continuing mandamus, for
monitoring compliance with the directions
nd
issued by this Court vide orders dated 22
th
August, 2025 and 7 November, 2025, in
addition to the directions contained in the
present order, and the same shall be placed
before and, as far as practicable, taken up by a
Division Bench of the concerned High Court.
B. The Registry of this Court is directed to
forthwith transmit a copy of the present order,
th
as well as the orders dated 11 August, 2025,
nd th
22 August, 2025 and 7 November, 2025, to
the Registrar Generals of all the jurisdictional
125
High Courts, for the purpose of ensuring
effective compliance, implementation and
monitoring of the directions issued therein.
C. While ensuring full compliance with the
directions issued by this Court, the concerned
Bench of the High Court shall be at liberty to
expand or tailor the scope of such directions, as
may be necessary to address local conditions
and exigencies, without in any manner diluting
the tenor and intent of the directions issued by
this Court.
D. It is made clear that any continued failure or
deliberate non-compliance with the directions
issued by this Court, including the directions
nd
contained in the orders dated 22 August,
th
2025, 7 November, 2025 and the present
order, shall render the erring officials of the
municipal department, administrative
authorities and the officials of the concerned
departments of the States and Union Territories
liable to appropriate proceedings in accordance
with law. The jurisdictional High Courts, while
undertaking the monitoring exercise in terms of
the present order, shall be fully empowered to
126
take appropriate action, including initiation of
contempt proceedings, against the erring
officials responsible for non-compliance,
inaction or wilful disregard of the directions
issued by this Court.
E. The Chief Secretaries and the Secretaries of the
relevant departments of all the States and
Union Territories shall file their updated
affidavits of compliance before the respective
th
jurisdictional High Courts on or before 7
August, 2026. Likewise, the Union of India and
the National Highways Authority of India shall
also file their respective affidavits of compliance
before the jurisdictional High Courts, in relation
to areas falling within their respective domain,
within the aforesaid period, clearly indicating
the measures undertaken in compliance with
the directions issued by this Court.
F. The Registry of this Court is directed to
forthwith transmit the records of all transferred
cases/applications to the respective
jurisdictional High Courts, and the matters so
transmitted shall be appropriately tagged and
heard along with the suo moto writ petition to be
127
registered by the High Courts in terms of
Direction (A) above.
G. The High Courts, through their respective
Registrars General, shall compile and forward a
consolidated report to this Court every four
months, summarising the status of compliance
by States and Union Territories, the progress
achieved, best practices identified, and
persistent gaps requiring policy or judicial
intervention. The first such consolidated
report shall be placed on record before this
Court at least one week prior to the next date
th
of hearing, i.e., 17 November, 2026.
112. The Registry is directed to forthwith transmit a
copy of this order to the Chief Secretaries of all States
and Union Territories, as well as to the Union of India
through the Ministry of Health and Family Welfare
and the National Highways Authority of India, to
ensure due compliance with the directions issued
herein.
113. In order to ensure uniformity, clarity and
effective monitoring of compliance with the directions
issued by this Court, all States and Union Territories
128
are directed to furnish their compliance affidavits
before the jurisdictional High Court in the prescribed
format appended hereto as Annexure titled
“Compliance Reporting Format (States/Union
Territories)”
, duly filled in with complete and
accurate particulars, along with supporting material
wherever necessary.
th
114. List the matter on 17 November, 2026, for
receiving the consolidated compliance reports to be
forwarded by the High Courts through their
respective Registrars General and for further
directions.
115. This Court places on record its deepest
appreciation for the assistance rendered by the
learned Amicus Curiae , which has greatly facilitated
an informed adjudication of the issues arising herein.
….……………………J.
(VIKRAM NATH)
...…………………….J.
(SANDEEP MEHTA)
..……………………..J.
(N.V. ANJARIA)
NEW DELHI;
MAY 19, 2026.
129
Annexure: Compliance Reporting Format
(States/UTs)
S.
No.
Particulars Details/Status (to be
filled by State/UT)
1 Total number of districts in
the State/UT
2 Number of functional ABC
Centres
3 Number of districts with at
least one ABC Centre
4 Details of additional ABC
Centres proposed/under
establishment
5 Total number of veterinarians
available for ABC programme
6 Total trained staff/personnel
deployed for ABC
implementation
7 Number of stray dogs
sterilised (last 6 months)
8 Number of stray dogs
vaccinated (last 6 months)
9 District-wise breakup of
sterilisation and vaccination
(Chart to be annexed
separately)
10 Identification of institutions
under Direction (A) of order
th
dated 7 November, 2025
11 Steps taken for removal of
stray dogs from institutional
areas
12 Steps taken for securing such
premises under Direction (B)
th
of order dated 7 November,
2025
130
13 Appointment of Nodal Officers
under Direction (C) of order
th
dated 7 November, 2025
14 Inspection mechanism under
th
Direction (D) of order dated 7
November, 2025
15 Statistics regarding Removal
and relocation of stray dogs
under Direction (E) of order
th
dated 7 November, 2025
16 Compliance with SOPs issued
by AWBI
17 Decision taken for extension
to other public areas
18 Availability of anti-rabies
vaccines
19 Availability of anti-rabies
immunoglobulin
20 Mechanism for coordination
21 Monitoring and reporting
mechanism
22 Budget allocation for ABC
implementation
23 Infrastructure gaps identified
24 Timeline for addressing gaps
25 Creation of helpline number
for reporting dog bite
incidents
26 Creation of dedicated feeding
spaces for stray dogs in each
municipal ward
27 Mechanism for adoption of
stray dogs
28 Any other relevant
information
131