Author: Himanshi Das,  Himachal Pradesh National Law University

 INTRODUCTION

On 11^th August, 2025 a landmark order was issued directing the removal of all stray dogs from Delhi NCR within a time span of six to eight weeks. The order has directed that the animals be relocated to shelters that are equipped with facilities for vaccination, sterilization, CCTV Surveillance. The order was passed as a response to the growing cases of death due to rabies after being bitten by the stray dogs. The order was passed by by two judge bench that comprised of Justice JB Pardiwala and Justice R. Mahadevan. The bench took a suo motu cognizance of the menace of stray dog attacks. The bench has used many statements pointing towards the graveness of the situation and the urgent action to control the danger. The bench gave statements such as- “infants and young children at any cost should not fall prey to rabies…. “All these animal activist, will they be able to bring back who have fallen  prey to rabies? The bench also warned that any objection and obstacles created in the execution of the order would call for contempt of court proceedings.  

CORE DIRECTIONS OF 11TH AUGUST 2025 ORDER:

1. Removal and relocation: There should be a  removal of all stray dogs in Delhi Ncr from the streets within six to eight weeks and shall be  relocated to te designated shelters.
2. Shelter facilities: there shall be arrangements for vacinization, sterilization and long term housing of these stray dogs and CCTV monitoring shall be present in these designated shelters. The arrangements should include feeding, medical care, and separate space for dog needing special attention to prevent death from cruelty and  overcrowding.
3. Penal Action: any person or organization that would try to obstruct the execution of the order would be penalized for the contempt of court. 
4. Adoption scheme: The stray dogs can be adopted only under 2022 AWBI Protocol, that ensures that no adopted dog is released back onto the streets.
5. Ban on release: the dogs should not be released back to the locality from where they were picked up .
6. Parallel implementation: The process of catching stray dogs shall run simultaneously while creating shelters. Removal of dogs cannot be delayed by citing lack of infrastructure.
7. Further proceedings: The matter will be taken up again for review after 4weeks along with a status report.
8. Rabies vaccine: NCT govt shall publish details of the availability of stock of rabies vaccine and give monthly report.            
9. Maintenance of record: Daily records should be maintatined of captured and sheltered dogs.
10. Helpline for dog bites: Upon receiving a complaint of dog bite the dog must be caught within 4 hours after a complaint is received on the helpline number.

TRIGGERS AND RESPONSE OF THE AUTHORITIES:

The trigger for the intervention of the court was a report that detailed the case of a six year old  Chavvi Sharma from Pooth Kalan locality. She was mauled by a stray dog and had developed rabies infection subsequent to which the girl died on 26^th July due to the  infection. The suo motu cognizance was taken by the Supreme Court by a two judge bench of Justice JB Pardiwala and Justice R Mahadevan. This incident was taken as a public interest matter. The court said that, the registry has been directed to treat the matter as a suo motu writ petition and place the order along with the news report before the Chief Justice of India for necessary directions. The supreme court emphasized that the safety of citizens and especially children and the elderly must come first.

The Chief minister of Delhi Rekha Gupta has pledged a swift implementation of the Order passed by the Supreme court. The court has given the directive to not entertain any objection from animal rights activists and have warned that any obstruction in the implementation of the

order would be taken a s a contempt of the court. The court has emphasized that there cannot be any compromise in the safety of the public. The Delhi mayor Raja Iqbal Singh has promised a planned, humane and time bound implementation of the court’s order. The mayor has initiated with removal of aggressive stray dogs and rabies infected dogs. The shelters have been expanded and the helpline has been launched to support the execution of the order.

ANALYSIS AND IMPLICATIONS OF THE ORDER:

The central govt. had announced the Animal Birth Control Rules 2023 in March 2023 under the Prevention of Cruelty to Animal Act 1960, it came as a presiding rule over the Animal Birth Control (Dog) Rules, 2001. The ABC Rules have addressed the guidelines that were laid down in the writ petition by the Hon’ble Court in the Animal Welfare Board of India v. People for elimination of Stray Troubles. The Hon’ble Apex court in its various orders have mentioned that the stray dogs shall not be relocated. The ABC programme included sterilization and immunization of the stray dogs that was to be carried by the municipalities and the respective local bodies. The ABC Rules 2023 provides a framework that involves guidelines to deal  with the  conflict between humans and stray dogs  and also gave the directive of not relocating the dogs of the area. According to the ABC Rules only the organizations recognized by the Animal Welfare Board of India shall carry out the ABC programme. 

The 11^th August 2025 order has been criticized and backlashed and has been called as inhumane, unscientific, and a legally flawed order by the Animal Welfare Groups. Former union minister and animal rights advocate Maneka Gandhi has called the order as “unworkable and costly”. The order has sparked a debte raising questions about its legality, practicality and morality. The order was later reserved on a plea that seeked stay on the directive to remove the stray dogs from the streets of Delhi NCR streets. The animal welfare groups and activists have raised several questions regarding the practicality and feasibility of the order:

• Availability of shelter

The animal welfare activists have raised questions on the availability of Government run shelters for these dogs. As per sources Delhi has only 20 Sterlisation centres for a population of around 10 lakh stray dogs that is clearly insufficient. The Supreme Court has ordered the municipal authorities to catch all the stray dogs and sterlise them and to keep them permanently in shelters. The appropriate infrastructure for accommodating such a large population requires both time and money. The Supreme Court has mandated the civic bodies to comply with the order within eight weeks which is practically unworkable. The dog lovers raises question regarding expanding shelters, trained staff in these shelters and arrangement of food for all the stray dogs that will be captured by the civic bodies that too in 2 months. The animal activists and the critics have raised doubts on numerous points regarding the welfare of the street dogs after this order:

• Financial Capacity

Animal rights activist Maneka Gandhi have raised doubts on the 15000 crore challenge. According to the activist there are three lakh dogs in delhi and to make enclosures that is approximately 3000 pounds for which each pound  would require a drainage, water supply, trained staff, kitchen and food for the dogs will require Rs15000 crores. She raised the question that does Delhi have this big amount to utilize it and implement the order? 

• Inadequate time period

The supreme court has given a time for 2 months for the civic bodies to comply with the order by initiating to build shelters for about 5000 dogs. That means the infrastructure, the food arrangements, the trained staff and security and budget all needs to be managed within a period of eight weeks, which currently seems unworkable for all the animal activists and dog lovers. 

• Vaccum effect

Shelters could turn into procreation ground for zoonotic diseases and parvovirus as the removal of sterlised dogs which are territorial in nature could lead to the “vaccum effect”. In this process the unvaccinated and more aggressive dogs will be cohabiting with the sterlised and vaccinated ones. 

COURT’S REVISED APPROACH: 22^nd AUGUST 2025 ORDER:

The Supreme Court by a three judge bench comprising of Justice Vikram Nath, Justice Sandeep Mehta and Justice N.V. Anjaria has modified its 11^th august order. According to the revised directions :

• Stray dogs are to be sterlised and vaccinated and should be released after their treatment
• Only the aggressive and infected stray dogs shall be sheltered, Emphasis have been put on the ABC Rules of 2023 that focuses on the vaccinization and sterilization of the stray dogs .
• Further, the court has directed that no public feeding is allowed, feeding of the stray dogs must take place only at a particular feeding zone.
• The Supreme Court has directed that all the similar cases to be transferred to the Supreme Court to develop a national policy.
• The court has directed the NGO’s and the dog lovers to deposit a security of 2 lakhs and 25,000 respectively

CONCLUSION AND WAY FORWARD:

The Supreme Court’s modified order shows an attempt to harmoniously reconcile public safety and a humane treatment to the controversy. The modified order has reflected the balance that is required to maintain public health and animal welfare. The modified order emphasizes importantly on the sterilization and vaccination of the stray dogs that shows a practical and humane approach. 

The challenge now lies in the implementation of the order that shall be effective by ensuring adequate infrastructure for the treatment of the stray dogs, the management of the feeding zones and the norms related to the security deposits. The success of the order will rely not only on these directions but with a coordinated effort by the NGO’s, the municipalities and the public aswell. The latest order thus if implemented effectively has the potential to change the Delhi NCR stray dog crisis.