Rabid Fears & Humane Hope: India's Community Dog Dilemma

The Hon’ble Supreme Court's decision to take cognizance of the stray dog issue represented the court's responsiveness to public safety concerns and in matters of urban policy. However, the initial order which was passed suo moto based on a newspaper article which the Hon’ble Court found deeply disturbing demonstrated it'spower to step in on matters it considers to be of public safety which becomes a matter of fundamental rights protection.  

During the initial hearing the amicus curiae based on the written submissions recorded it appears that he had limited to no systematic engagement with animal welfare experts, veterinary professionals, and urban planning specialists during the initial phase. Complex urban challenges typically benefit from expert committee consultations that can provide technical guidance. The matter's progression suggests that broader stakeholder consultation might have resulted in more practical and sustainable initial directions. Additionally, the suo motu nature of the case, while demonstrating judicial concern for public welfare, may have limited the range of perspectives initially considered. In fact, the original directive's focus on "permanent sheltering" raised practical questions about implementation feasibility as well as prima facie appeared to contrary to the Animal Birth Control (ABC) Rules, 2023 . 

India's existing public animal shelter infrastructure is still insufficient for mass accommodation, and the directive did not appear to account for the resource implications, timeline requirements, or welfare standards necessary for such an undertaking. Animal welfare organizations, veterinary associations, urban planners, and municipal experts could have provided valuable insights into implementation challenges and alternative approaches. The need for such significant modification suggests that more comprehensive preliminary analysis might have prevented the initial directive's practical difficulties. The original directive, while well-intentioned in addressing urgent public safety needs, appears to have been formulated without comprehensive consideration of ground realities, existing infrastructure capacity, and stakeholder perspectives.  

 Significance Of Full Bench Formation  

The transfer from a two-Judge bench indicates that the Hon’ble Court perceives this as a matter requiring precedent-setting that will have implications especially in light of an earlier conflicting order. The intervention by the Chief Justice of India in referring the matter to a Full Bench, which then modified the earlier directions for immediate removal of stray dogs, demonstrated judicial responsiveness to public safety concerns, but raised questions about the thoroughness of the initial consultative process.  

The subsequent constitution of a three-judge bench and the 22nd August, 2025 Interim Order demonstrated the judicial system's capacity for institutional learning and course correction. The matter now signifies the court's recognition of the matter's complexity and far-reaching implications. Full bench formation typically occurs when the matter involves substantial questions of law, conflicting precedents, or issues of national importance.  

 The full bench interim order aligned more with the Animal Birth Control (ABC) Rules, allowing release after sterilization while prohibiting public feeding, represents a more nuanced understanding of the technical and practical aspects of animal population management.  

 The full bench's approach shows greater appreciation for the Animal Birth Control (ABC) programs as effective population management tools. The Court's recent modification allowing release after sterilisation while prohibiting public feeding in non designated feeding spots represents an attempt to balance these concerns, but implementation will now be crucial.   

The Apex Court’s decision to transfer similar pending cases from various High Courts to the Supreme Court ensures uniform policy development rather than potentially conflicting regional approaches. This expansion acknowledges that stray dog management is not a Delhi-specific challenge but a nationwide urban challenge requiring coordinated policy responses. By bringing all states and union territories under the same judicial framework, the court has created an unprecedented opportunity for standardized, evidence-based compassionate animal management policies across India. 

 Divided Public Sentiment  

Those fearful of dogs, often including families with young children, elderly residents, and those who have experienced dog attacks, see the judicial intervention as long-overdue relief from a problem that has made public spaces unsafe for them. They argue that animal welfare concerns should not override basic public safety and that previous policies have prioritized dogs over human safety.   

 Conversely, proponents of Animal welfare, view stray dogs as sentient beings deserving compassion and protection. They argue that properly managed ABC programs (as per prevailing law), combined with responsible feeding & community involvement, can address population concerns while maintaining animal welfare standards. For this group, the initial judicial intervention represented a rollback of progressive animal welfare policies.  

 There was apprehension about the practical implementation of the Hon’ble division bench court's interim directions. The earlier directive for immediate removal & permanent sheltering raised legitimate concerns about the capacity of existing shelter infrastructure and the palpable potential for inhumane treatment of captured animals.  

Second, animal rights groups fear that this judicial intervention might provide cover for municipal authorities to abandon a balance between public safety & animal welfare already elucidated in Animal Birth Control (ABC) Rules, 2023 in favour of more draconian measures potentially leading to mass culling or other inhumane practices under the guise of judicial sanction.  

Systemic Failures of Policy Implementation & Administrative Negligence  

Pursuant to the Supreme Court’s cognizance it appears that the Ministry of Animal Husbandry reiterated on ABC rules and programs indicating a policy preference for systematic, humane management approaches rather than mass removal or culling. The ministry's approach emphasizes scientific Animal Birth Control methods, systematic vaccination programs, and co-ordinated efforts between central, state, and local governments (such as Municipal Corporations).  

However, there was, and still is, a clear systematic failure of Municipal Corporations in Delhi (MCD) similar to the case in some other Indian cities as well to implement effective Community Dog management programs. The corporation's inability or unwillingness to implement existing Animal Birth Control programs effectively, despite clear legislative frameworks and central government guidelines, highlights an alarming gap between legislative intent and administrative execution.  

The Delhi Municipal Corporation at both instances, abstained from providing reasons for their consistent failure to undertake the same, but in all likelihood, would attribute this to, budget constraints, lack of infrastructure, & administrative inefficiencies as reasons for poor implementation which indicate a failure to recognize animal population management as an urban governance responsibility. Systematic sterilization, vaccination and responsible feeding practices in designated areas, could have and still can significantly reduce(d) both the stray dog population and incidents of rabies.  

The implementation challenges became starkly evident in the recent controversy surrounding the Animal Birth Control (ABC) Centre in Rohini Sector 27. Shocking visuals appeared from Delhi's Rohini ABC Centre showing cruel and inhumane conditions with photos and videos pointing to cruelty against stray dogs inside the centre. The incident highlighted fundamental problems with facility standards, veterinary care protocols, and oversight mechanisms that the Supreme Court's framework had intended to address. The controversy serves as a stark reminder that sustainable solutions require not just legal frameworks but robust implementation capacity, professional standards, and transparent monitoring systems that can prevent such institutional failures from occurring again. 

Practical Roadmap Forward  

  A practical, humane, and legally sound resolution requires strategy that addresses concerns while maintaining constitutional principles. A truly effective solution requires finding a balance for both public safety concerns as well as animal welfare principles.  

First, immediate scaling up of shelter infrastructure with humane conditions as well as proper veterinary care, ensuring that even temporary relocation of dogs for vaccination or treatment is conducted as per prevailing ABC Rules only with complete transparency. Second, rapid implementation of systematic ABC programs with adequate funding, professional veterinary services, and community involvement. Third, designation of specific feeding areas with equal representation between local communities animal welfare groups, and municipal authorities.  

Additionally, comprehensive public education campaigns about compassion towards community dogs and other animals, as well as first aid for dog bites could reduce both incidents and public fear. Increased availability and either free or extremely subsidized rabies vacines as well as regular monitoring, evaluation, and public reporting by the administration of all management programs would ensure sustained implementation.  

Long-term solutions require sustainable funding mechanisms for animal welfare programs, potentially through dedicated monetary government support. Professional veterinary service networks that provide consistent, high-quality care for community animals need to be developed. Integration of animal welfare considerations into urban planning and development processes will prevent future crises. There should also be an emphasis on comprehensive municipal capacity building with dedicated staff, infrastructure, and budgets for animal welfare and management programs with full transparency to the public. Community outreach programs at a sub-Ward level that involve residents, animal welfare groups, and local authorities in collaborative solutions should be implemented.  

The path forward must acknowledge that both public safety and animal welfare are legitimate concerns that can be addressed simultaneously through systematic, well-funded, and professionally managed programs. Successful stray animal management programs typically involve sustained institutional commitment, professional expertise, and community engagement over extended periods. Cities like Istanbul, Bucharest, and several Indian cities like Dehradun & Lucknow have demonstrated that effective programs require institutional continuity, technical expertise, and adequate resource allocation maintained over years rather than months.  

Challenges & Ground Realities 

The recognition that dog bite incidents violate fundamental rights under Articles 19(1)(d) and 21 provides the constitutional foundation for judicial intervention, while an emphasis on compassion toward living beings reflects Directive Principles under Article 48. 

The success of the court's modified approach depends heavily on implementation capacity, which has been the Achilles' heel of previous animal management efforts. The court's judgment ordered designating feeding spaces across the capital. However, there is an apprehension as far as the portion of the order which applies the same treatement to rabid dogs as dogs that are  “suspected to be infected with rabies, and those that display aggressive behaviour” since it is possible that the terms above can be interpreted differently by different members of society based on mere apprehensions or lack of expert insight.   

The designation of specific feeding areas represents a compromise between animal welfare advocates who argue that feeding is essential for animal health and those who contend that unregulated feeding contributes to territorial behavior. However, the practical implementation of such designated areas requires coordination between municipal authorities, resident communities, and above all active animal welfare groups. This balancing act represents the complexity of constitutional interpretation in matters where different rights and values may appear to conflict.  

Toward Sustainable & Compassionate Animal Welfare and Human Rights  

The Supreme Court's evolving approach to community dog management represents a significant development in Indian jurisprudence, urban governance, and animal welfare policy. The success of this approach will depend on effective implementation by municipal and state authorities, continued stakeholder cooperation, and sustained commitment to both public safety and animal welfare objectives.  

The precedent established through this case may influence how India addresses other urban governance challenges, potentially strengthening the legal and administrative frameworks necessary for effective metropolitan management in an increasingly urbanized nation. The ultimate measure of success will be whether this judicial intervention results in safer communities and better animal welfare outcomes, demonstrating that constitutional values and practical urban management can be effectively harmonized. 

The Supreme Court's eventual course correction demonstrates institutional capacity for learning and adaptation, while the MCD's persistent failures highlight the need for more fundamental administrative reforms. Moving forward, both institutions can benefit from systematic analysis of this experience to improve their approaches to similar challenges. Effective resolution of complex urban issues such as this requires institutional designs that combine judicial oversight with administrative expertise, technical competence with democratic accountability, and immediate responsiveness with long-term sustainability and above all compassion for both two legged as well as the four legged that we share our land with.  

The writer, Siddharth Chandrashekhar, is an Advocate practicing at the Bombay High Court. He frequently write on issues at the intersection of law, public policy, and social impact.

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