INTRODUCTION
A Delhi Morning, where a six-year-old girl is yelling between the packed strays, resulting in claiming her life, looks like a crime story? But it is one of the countless tales from Delhi and NCR. The stray dog estimation of around 1-1.5 million has contributed to public safety and health nightmares[1]. The fatal incident involving a six-year-old girl and 26,334 dog-bite complaints in 2024 has fueled the rage of fear amongst the region of Delhi and NCR. Rabies being the deadliest result of this has become a great concern for the region, it is astonishing to know that India single-handedly bears the number of 35% of world death[2] (annually approximately 59,000) through rabies, the reason for the cause includes- Dog bites, inadequate waste management which attracts the stray dogs and inconsistent sterilization efforts under the Animal Birth Control rules (2001), have resulted in population rise and accordingly boosts the rabies death rate.
BACKGROUND
‘CITY HOUNDED BY STRAY, KIDS PAY PRICE’- a news report in the Delhi edition of Times of India, which included very disturbing facts and figures. A trainee Journalist named Kaushiki Saha wrote an article which mentioned the death of a six-year-old girl in a stray dog attack[3]. The incident questions the negligence of local authorities, State government for not taking any action despite repeated complaints. The bench of Justice Mahadevan and Justice Pardiwala initiated a suo motu on July 28 following the above news report. The bench was shocked to look at the estimates that around 20,000 dog-bite cases are recorded in India, out of which 2000 are only from Delhi[4]. Another incident that contributed to this decision was of a four-year-old boy named as Abhishek Rai, who was attacked by a pack of stray dogs while he was returning from his school. These reports showing escalating attacks on the aged and children, which violate the person’s right to life under Article 21 of the Constitution of India[5], were noted by the bench. The Animal Birth Control (2001), revamped in 2023, promised sterilisation and vaccination of freely roaming dogs, but what about its implementation? Only 70% of the Delhi area was covered under this process, leaving the other 30% in a nightmare.
JUDICIAL RESPONSE
The bench came up with a judgment which authorised the responsible authorities to start picking up the stray dogs as soon as possible, and a necessary force can be created during the course of this process. The court also directed the authorities that a dog shelter for about 5000 dogs must be immediately created and to provide an update with respect to the creation of such infrastructure within eight weeks. The court also directed the authorities that the shelter must have sufficient personnel to sterilise, immunise, immunize and deworm and take care of the stray dogs. The court also made it clear that the detained dogs should not be released back to the streets. The court had to face several oppositions to this judgment from several animal rights activists, common people, NGO’s, etc. Think tank Esya Centre has released a research paper named ‘FREE RANGING DOGS IN INDIA: AN EMPIRICAL ANALYSIS OF HUMAN- ANIMAL INTERACTION’[6], which provides a new level of data on dog management, which is contrary to the views of the Supreme Court. According to this research paper, rabies deaths in India have considerably declined over the past 2 decades. The numbers show that between 2022 and 2025, only 126 rabies-related deaths were recorded nationwide, while Delhi reported no deaths during this period, indicating the success of Animal Birth Control (ABC) and Anti- Virus Vaccination program.
The Supreme Court had modified its August 11 orders of picking up the stray dogs and keeping them in dog shelters, and limited to sterilise, deworm, vaccination and then release back to the same place from where they were picked- except those suffering from rabies or showing aggressive behaviour. This issue is emotionally connected to people and animal lovers, hence a holistic approach which focuses on both human issues with animal welfare was adopted by three- judges bench of Justice Vikram Nath, Justice Sandeep Mehta, Justice NV Anjaria. The court has directed the municipal authorities across the country to ensure that only sterilised and vaccinated dogs are returned to their original areas. On the other hand, aggressive animals and those suffering from rabies should be kept in shelters.
IMPACT
There are around 30 million dogs in India and their population is rapidly growing because of lack of adequate facilities of shelters, lack of vaccination and sterilization which gives up the deadly cases of rabies, hence on the outcome of this Supreme Court has passed order of picking up the dogs and placing them to the shelters, but the result of this decision was not accepted by activist hence on 11th August CNVR i.e. Catch, Neuter, Vaccination and Release scheme was adopted. This resulted in a total of 54,623 dogs being sterilised in Delhi over the last six months, which was submitted by the Municipal Corporation of Delhi (As per an article by the Indian Express)[7]. Another report by the Municipal Corporation of Delhi shows that adoption rates of dogs have surged to 30%.
CRITICISM FROM CONSERVATIONISTS
The earlier Supreme Court decision to permanently remove stray dogs from the streets immediately ignited widespread and vigorous opposition from conservation biologists, animal welfare organisations, and legal experts who deemed the policy impractical, unscientific and fundamentally inhumane. Some of them are as follows:[8]
- Conservation Biologist Bahar Dutt said in X, calling this move impractical and unscientific, “Where are the shelters to house thousands of dogs?” was his question.
- The founder of Animal Welfare Organisation wrote on social media that, “We respectfully believe the focus should be on humane solutions for street dogs in Delhi, mass vaccination and sterilisation, rather than removal.”
CONCLUSION
The Supreme Court, on the contrary, was of the view that “Will they bring back the lost lives?” The statement given by the Supreme Court was not completely incorrect, hence at last holistic approach was adopted and concerns were given to both Human lives and animal welfare. The latter Judicial Correction of reaffirming the earlier verdict and directing the authorities to use the CNVR (Catch, Neuter, Vaccinate and Return) scheme was a significant victory for both public health and animal welfare. It is the responsibility of the civic bodies to comprehensively execute the Animal Birth Control (ABC) and Anti- Ragging Vaccination program across the country, through awareness and vaccination campaigns in schools for children. Systematic decomposition of solid waste is also an essential step, as this mismanaged waste attracts stray dogs, which infect them and ultimately pass it through their bites to others. As mentioned earlier only 70% of Delhi region are done with dog sterilization and vaccination, leaving the pending 30%, which should be covered as soon as possible, the government must also focus on all nation CNVR scheme especially in those urban and semi- urban areas which is packed by humans and dogs, the initiative is difficult to achieve but an amalgamation of government and public sustenance will surely achieve it.
Author’s Name: Aadin Reddiar (Adv. Balasaheb Apte College of Law, Mumbai)
[1] Esha Mitra and Rhea Mogul, ‘One million stray dogs in India’s capital regain the right to roam after legal battle with nation’s top court’ (CNN World, 23 August 2025) <https://edition.cnn.com/2025/08/22/india/india-stray-dogs-supreme-court-intl-hnk-dst> accessed 4 November 2025
[2] World Health Organization, ‘Global burden of dog- transmitted human rabies’ (WHO, 17 February 2018) <https://www.who.int/teams/control-of-neglected-tropical-diseases/rabies/epidemiology-and-burden> accessed 5 November 2025
[3] Soumya Sylka Sahoo, ‘ Case Comment: In Re: City Hounded by strays, kids pay price’ (2025) 7(4) IJLLR <https://www.ijllr.com/post/case-comment-in-re-city-hounded-by-strays-kids-pay-price-suo-moto-writ-petition-civil-no-5-of> accessed 5 November 2025
[4] V. Venkatesan, ‘Stray dog ‘menace’: Making sense of the Supreme Court’s intervention’ (SCO, 16 August 2025) <https://www.scobserver.in/journal/stray-dogs-menace-making-sense-of-the-supreme-courts-intervention/> accessed 5 November 2025
[5] Constitution of India 1950, art. 21
[6] By a representative of Counter view, ‘Think tank warns against removal of stray dogs, cites evidence of public safety benefits’ (Counter View, 4 November 2025) <https://www.counterview.net/2025/11/think-tank-warns-against-removal-of.html> accessed 5 November 2025
[7] Amaal Sheikh and Drishti Jain, ‘Over 54,000 stray dogs sterilised in 6 months, MCD tells SC; data shows month-on-month dip’ The Indian Express (28 October 2025) <https://indianexpress-com.cdn.ampproject.org/v/s/indianexpress.com/article/cities/delhi/over-54000-stray-dogs-sterilised-in-6-months-mcd-tells-sc-data-shows-month-on-month-dip-10330922/lite/?amp_gsa=1&_js_v=a9&usqp=mq331AQIUAKwASCAAgM%3D#amp_tf=From%20%251%24s&aoh=17623412380467&referrer=https%3A%2F%2Fwww.google.com&share=https%3A%2F%2Findianexpress.com%2Farticle%2Fcities%2Fdelhi%2Fover-54000-stray-dogs-sterilised-in-6-months-mcd-tells-sc-data-shows-month-on-month-dip-10330922%2F> accessed 5 November 2025
[8] Louis Oelofse, ‘Law and Justice| India (DW, 8 November 2025) <https://www.dw.com/en/india-court-orders-removal-of-5000-stray-dogs-in-new-delhi/a-73597706> accessed 5 November 2025
