By Mohd Farhan
On August 11, 2025, in In Re: Stray Dog Menace in Delhi-NCR (Suo Motu Writ Petition, 2025), the Supreme Court delivered a landmark judgment directing the immediate capture, sterilization, vaccination, and sheltering of all stray dogs in Delhi-NCR. The ruling emerged from suo motu cognizance of a media report titled “CITY HOUNDED BY STRAYS, KIDS PAY PRICE”, highlighting the alarming surge in dog bite incidents and rabies cases.
On the Press Information Bureau website, data on the number of dog bites for the years 2022, 2023, 2024, and 2025 [January] have been published. Exactly, 37,15,713 dog bites were reported nationwide in 2024. There were 25,201 dog bites in Delhi alone. Three thousand and sixteen hundred dog bites occurred in Delhi in January 2025. As per the table below, the number of dog bite instances has increased during the past three years. According to data from January 2025, there has been a 50% increase in dog bite cases.
Dog Bite cases reported by States/UTs at IDSP [from 2022-2025]
| 2022 | 2023 | 2024 | 2025 (January) | |
| Delhi | 6,691 | 17,874 | 25,210 | 3,196 |
| India | 21,89,909 | 30,52,521 | 37,15,713 | 4,29,664 |
From ABC to a New Urban Model
Until now, stray dog management in India has largely followed the Animal Birth Control(ABC) Rules, 2023, based on the “catch–neuter–vaccinate–release” (CNVR) model. While effective in some rural and semi-urban contexts, the Supreme Court had then found this approach inadequate for densely populated urban centres. The Bench, led by Justice Sanjiv Khanna (now retired) and Justice Dipankar Datta, termed the release of sterilised dogs back into high-density public spaces “a cycle that endangers both human safety and animal welfare.”
Core Directives of the Judgment
• Capture & Care: All stray dogs, sterilised or not, must be removed from streets and shifted to shelters.
• Shelter Standards: Humane conditions, adequate space, veterinary care, and no overcrowding.
• Timeline & Helpline: 6–8 weeks for shelter construction; a helpline operational within one week for responding to bite complaints within four hours.
• No Return Policy: Released dogs to the streets is strictly prohibited, even after adoption.
• Enforcement: Civic bodies in Delhi, Noida, Gurugram, Faridabad and Ghaziabad warned of penal action for non-compliance; obstruction could invite contempt proceedings.
Judicial Reasoning and Constitutional Grounding
The Court grounded its decision in Article 19(1)(d) (freedom of movement) and Article 21(right to life), asserting that “fear of animal attacks undermines citizens’ constitutional liberties.” Citing Animal Welfare Board of India v. A. Nagaraja (2014), 7 SCC 547, the Bench reiterated that animal welfare is part of our constitutional ethos, but clarified that public safety cannot be subordinated to uncontrolled urban animal populations. A significant proportion of traffic accidents that result in injury or fatalities to other road users are also caused by stray dogs. Even if a person may not die from a dog bite, he may still fall or collide with another car as a result of his evasive behaviour, which could cause death or serious harm. Therefore, the decision aims to create a harmonious structure that protects human life and dignity while also treating stray animals humanely. Why the Supreme Court’s Stand Deserves Support
Addressing Two Systemic Failures
1. Inadequate Urban Implementation of ABC Rules: Chronic underfunding, lack of vaccination coverage, and insufficient monitoring have allowed urban stray populations to grow unchecked.
2. Absence of Emergency Protocols: In the face of rising rabies cases, civic bodies lacked a rapid, humane, and scalable response framework.
By mandating dedicated shelters, veterinary care, and swift complaint mechanisms, the judgment introduces an urban-specific management model. This could set a precedent for other metropolitan areas facing similar crises, where CNVR alone has proved insufficient.
The perspective of opponents argue that the six-to-eight-week timeline is unrealistic, that mass sheltering could lead to overcrowding and stress for the animals, and that the ruling diverges from internationally accepted CNVR strategies. These concerns are not unfounded—without sufficient infrastructure and funding, the risk of poorly managed shelters is real. Yet, the urgency of the public health crisis, coupled with the Court’s insistence on humane conditions, suggests that the ruling is less a rejection of CNVR in principle and more an immediate, targeted remedy for an acute urban problem. Proper execution by civic authorities will determine whether this judgment becomes a model of compassionate governance or a cautionary tale.
Additional Public and Animal Welfare Benefits
The judgment’s impact goes beyond curbing the stray population—it also delivers tangible safety and welfare gains. Removing dogs from high-traffic streets can drastically cut road accidents caused when animals suddenly cross in front of moving vehicles. Vulnerable groups, such as people sleeping on footpaths, will face a reduced risk of night-time dog bites from unowned and unsheltered animals. At the same time, relocating strays to properly managed shelters ensuresthey receive regular food, clean water, and veterinary care. This transforms their lives from uncertain street survival to secure and humane living, creating a win–win outcome where both citizens’ safety and animals’ dignity are protected.
Conclusion
The Supreme Court has taken a bold and necessary step to address an escalating public health and safety crisis, without abandoning India’s commitment to animal welfare. Among a bundle of concerns, courts have taken cognisance of the experiences of visually impaired persons, young children, elderly persons, people from humble backgrounds who cannot afford even a day’s meal, let alone medical expenses. Visually impaired persons are at the highest risk of dog bites as their canes are seen by dogs as threats. Due to the risk of dog bites, parents find it extremely challenging to let their young children walk the streets alone. We have encountered reports of noisy dogs attacking senior citizens. Additionally, it reduced the number of accidents that occurred because of dogs accidentally running in front of cars. If implemented with adequate resources and oversight, this directive could serve as a model for humane urban animal control across the nation—protecting both the rights of citizens and the dignity of the voiceless.
—Mohd Farhan is a first-year B.A.LL.B. student of Asian Law College, Noida