Supreme Court Modifies Stray Dog Directions | Bars Street Feeding, Mandates Dedicated Zones | Vaccinated Dogs to Be Released Except Aggressive or Rabies-Infected
Kiran Raj
The Supreme Court of India’s three-Judge Bench of Justice Vikram Nath, Justice Sandeep Mehta, and Justice N. V. Anjaria has delivered significant directions on the issue of stray dogs and public safety. The Court held that while the intent of its earlier order was to protect citizens, the directions required modification to align with statutory provisions and practical feasibility. The Bench directed that stray dogs, once sterilised, dewormed, and vaccinated, should generally be released back into the same localities, except in cases of rabies-infected or aggressive dogs. The Court further ordered the creation of designated feeding zones, mandated compliance reporting by municipal authorities, and expanded the matter to cover all States and Union Territories.
The matter originated when a two-Judge Bench of the Supreme Court took suo moto cognizance on 28 July 2025 of a news report published in The Times of India titled “City Hounded by Strays, Kids Pay Price”. The report highlighted the death of a six-year-old girl in Delhi from rabies following a dog attack, and the family’s allegations of administrative apathy. Taking note of the situation, the Court issued wide-ranging directions on 11 August 2025, mandating immediate steps by authorities across the National Capital Region (NCR).
The initial directions required authorities in Delhi, Ghaziabad, NOIDA, Faridabad, and Gurugram to round up stray dogs, place them in shelters or pounds, and ensure sterilisation, deworming, and immunisation. The Court ordered that, under no circumstances, should the dogs be released back on the streets, and warned that any hindrance in implementing the directions would be treated as contempt of court.
Following this, several interlocutory applications were filed by individuals and organisations describing themselves as “animal lovers.” They sought a stay on the directions, arguing that the order conflicted with the Animal Birth Control Rules, 2023 (ABC Rules). The applications asserted that Rule 11(19) of the ABC Rules requires that sterilised and immunised dogs be released back to the same area they were picked up from.
Among the related cases considered were Special Leave Petition (Civil) No. 14763 of 2024, filed by the Conference for Human Rights (India) (Regd.), challenging an order of the Delhi High Court dated 18 August 2023, which had expressed satisfaction with the sterilisation measures undertaken by the Government of NCT of Delhi (GNCTD) and the Municipal Corporation of Delhi (MCD). Another case, Special Leave Petition (Civil) No. 17623 of 2025, arose from an Allahabad High Court judgment dated 3 March 2025, where a resident of NOIDA had raised concerns about harassment faced while feeding community dogs. That High Court, noting the ABC Rules, directed authorities to balance public movement on streets with dog feeding measures.
Additionally, Writ Petition (Civil) No. 784 of 2025 was filed by an individual seeking maintenance of status quo and opposing the non-release directions contained in the earlier Supreme Court order.
The petitioners, identified as NGOs and individuals working for animal welfare, contended that the municipal authorities had already begun rounding up dogs and harassing feeders. They feared that due to lack of infrastructure, the authorities would resort to mass culling under the guise of compliance. They highlighted that nearly 700 dogs had already been picked up, and their fate was unclear.
The petitioners further argued that the contempt warning against individuals opposing the directions violated Article 19 of the Constitution, as it curtailed the right to free expression. They expressed apprehensions that lakhs of stray dogs, including newborn puppies, might lose their lives due to practical inability of municipal bodies to create sufficient shelter capacity.
On the other hand, the Solicitor General of India, Shri Tushar Mehta, appearing for GNCTD, submitted that while the challenge was enormous, the authorities were committed to complying with the Court’s earlier order. He cited reports estimating 37,15,713 dog bites in India during 2024, many of which resulted in trauma or rabies deaths. He stated that aggressive stray dogs posed a grave threat, especially to children and the elderly, restricting their access to streets and parks.
Shri Mehta maintained that sterilisation alone would not prevent dog attacks or rabies infection, as immunised but aggressive dogs could still inflict severe harm. He contended that the directions were not contrary to the statutory framework but were interim measures to safeguard citizens’ right to life under Article 21 of the Constitution. He urged that the measures remain in force until the population of stray dogs is brought under control, after which they could be reviewed.
In view of these submissions, the three-Judge Bench was called upon to clarify, modify, or reaffirm the earlier order of 11 August 2025. The Bench considered whether the mandatory directions should be tempered to ensure compliance with the ABC Rules while balancing public safety and animal welfare.
The Court recorded that while the purpose of the earlier order was laudable, a balancing approach was necessary. The Bench stated: “There is not even the slightest doubt in our minds that the intent behind the order is salutary inasmuch as it works towards protecting the citizens at large from the attacks by the aggressive and rabid stray dogs.”
At the same time, the Court recognised the statutory mandate under Rule 11(19) of the ABC Rules, noting: “The framework of the ABC Rules, to be specific, Rule 11(19) clearly provides that once the stray dogs have been sterilised, inoculated, and dewormed, they have to be released back in the same locality from which they were picked up.”
The Bench observed that the directions prohibiting release were aimed at avoiding a “vicious circle” where sterilised dogs would again populate the streets. However, it acknowledged the logistical impossibility of indefinitely housing all stray dogs: “One cannot be ignorant of the fact that the mandate to keep all the stray dogs, picked up from Delhi and the adjoining NCR cities, in the municipal shelters/pounds would require logistics of gargantuan proportions including manpower, shelters/pounds, veterinarians, cages and specially modified vehicles.”
The Court further noted the scientific reasoning behind the ABC Rules: “The provision in Rule 11(19) that the dogs, upon sterilisation and immunisation, should be relocated to the same locality from which they have been picked up, is scientifically carved out… it prevents overcrowding in the dog shelters/pounds and ensures compassionate treatment.”
Considering evidence presented, the Bench recorded that sterilisation measures in certain towns had reduced stray populations: “It was pointed out that towns like Dehradun and Lucknow, which have taken aggressive measures for sterilisation, etc., as per the ABC Rules, have seen a steady decline in the population of stray dogs.”
While agreeing with the broader intent of its earlier order, the Court remarked: “The direction given in the order dated 11th August, 2025, prohibiting the release of the treated and vaccinated dogs seems to be too harsh, in our opinion.”
The Bench stressed the importance of evaluating municipal capacity before issuing blanket directions: “Before any direction for impounding the entire stray dog population is given, it would be necessary to have a look at the existing infrastructure and human resources available with the municipal bodies. A blanket direction… may lead to a catch-22 situation.”
The Court modified and supplemented the earlier directions as follows. It ordered that municipal authorities must continue compliance with paragraphs 12(i) and 12(ii) of the earlier order, namely, the rounding up of stray dogs and creation of shelters. However, it suspended the part of the directions prohibiting release, clarifying that sterilised, dewormed, and vaccinated dogs must generally be released back into the same areas.
The Bench directed: “The dogs that are picked up shall be sterilised, dewormed, vaccinated, and released back to the same area from which they were picked up. It is, however, clarified that this relocation shall not apply to the dogs infected with rabies or suspected to be infected with rabies, and those that display aggressive behaviour. Such dogs shall be sterilised and immunised, but under no circumstances should they be released back onto the streets.” These animals were to be held in separate shelters after treatment.
The Court further ordered municipal authorities to create designated feeding spaces in each ward: “Gantry/notice boards shall be placed near such designated feeding areas, mentioning that stray dogs shall only be fed in such areas. Under no condition shall the feeding of stray dogs on the streets be permitted.” Violators were to be proceeded against under the law.
Additionally, the Court directed each municipal authority to establish helplines for reporting violations, with action mandated against individuals or organisations obstructing enforcement. The Bench modified the earlier contempt clause, stating: “In case any public servant acting in compliance with the aforesaid directions is obstructed, then the violator/s shall be liable to face prosecution for obstructing the public servant acting in discharge of official duty.”
The Bench required NGOs and individuals who had approached the Court to deposit sums of Rs. 2,00,000 and Rs. 25,000 respectively, with the Registry within seven days, with the funds to be used for dog welfare infrastructure. It also permitted adoption of street dogs through municipal applications, making it the responsibility of adopters to ensure the dogs did not return to streets.
Furthermore, municipal authorities were ordered to file affidavits detailing available resources, including veterinarians, pounds, personnel, and vehicles, to demonstrate capacity to comply with the ABC Rules.
Significantly, the Court expanded the scope of the matter to all States and Union Territories, impleading their respective Animal Husbandry and local body Secretaries, and directed the Registry to collect information about pending writ petitions in High Courts on similar issues for transfer to the Supreme Court. The matter is listed after eight weeks for compliance review.
Advocates Representing the Parties
For the Respondents: Senior Advocates Kapil Sibal, Dr. Abhishek Manu Singhvi, Siddharth Luthra, Krishnan Venugopal, Colin Gonsalves, Aman Lekhi, Siddharth Dave, and Additional Solicitor General Archana Pathak Dave, representing the Municipal Corporation of Delhi (MCD).
Case Title: In Re: City Hounded by Strays, Kids Pay Price
Neutral Citation: 2025 INSC 1018
Case Number: Suo Moto Writ Petition (Civil) No(s). 5 of 2025, with connected matters
Bench: Justice Vikram Nath, Justice Sandeep Mehta, Justice N. V. Anjaria
