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• The Supreme Court allowed euthanasia of rabid, incurably ill, dangerous and aggressive dogs to curb threat to human lives.

• In its judgment on May 19, the apex court said the right to live with dignity encompasses the right to move freely without the threat of harm from canines. 

A bench of justices Vikram Nath, Sandeep Mehta and N.V Anjaria, dismissed all the petitions and applications for recall, modification of the November 7, 2025 order including directive on relocation and sterilisation of dogs from institutional areas.

What was the earlier order of the SC?

• In its verdict on November 7, 2025, the Supreme Court highlighted the grave and continuing threat posed by the unchecked presence of stray animals, both on public roads and within institutional premises such as educational institutions, hospitals, sports complexes, bus stands/depots 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.

• 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.

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• Recognising the systemic inadequacies in the enforcement of existing statutory frameworks, including the Animal Birth Control Rules, 2023, and the evident lack of coordinated administrative action, the court issued a set of uniform and binding pan-India directions.

• The court imposed a mandatory obligation upon the jurisdictional municipal bodies/authorities to 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.

• Following the judgment, a large number of interlocutory applications came to be instituted before the court by various animal welfare organisations, associations, and individuals seeking intervention in the proceedings. Several applications also sought for modification, clarification, vacation, recall and/or stay of certain directions contained in the order, particularly those pertaining to the removal of stray dogs from institutional areas and the prohibition on their re-release at the same locations.

Failure to implement Animal Birth Control framework

• 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-Sterilise-Vaccinate-Release (CSVR) model as the principal method for controlling the stray dog population, thereby prohibiting indiscriminate culling of stray dogs and mandating municipal authorities to manage sterilisation, vaccination, and sheltering in coordination with animal welfare organisations.

• The Animal Birth Control framework was subsequently revised and strengthened by the ABC Rules, 2023.

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• 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.

• Records reveal that the implementation of the Animal Birth Control framework has, in large measure, remained sporadic, under-funded and uneven, 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.

• 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. 

What the court highlighted in the latest order?

• The right to live with dignity under Article 21 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. 

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• 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.

• 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 may 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.

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