Dogs have been part of human life for ages and have been fulfilling roles such as friends, hunters, herders, police partners, and even sources of comfort. In Hinduism, dogs are often symbolised as loyal protectors and guardians of moral values. We can see them alongside Gods like Bhairava and Yama. India is home to an estimated 75 million dogs, including the free-roaming community variety.
In the vibrant environments of Delhi NCR and other cities, many residents are kind to community dogs, however, there are people who are also wary of them. The reasons mainly being, rise in dog bites, rabies, and extreme territorial behaviours. Such circumstances stressed the ability of humans and dogs to co-exist. This got worsened after a recent ruling by the Supreme Court of India that called for the removal of community dogs from public areas, an event which sparked a heated discussion about public safety and the extent of animal rights in India.
On 11th August 2025, the Supreme Court mandated the relocation of all street dogs in Delhi NCR to shelters. This order was altered on 22nd August 2025, which permitted the release of healthy and non-aggressive dogs back into their original neighbourhoods, while also banning feeding in public. This revised order seemed to be more scientifically sound, as it mandated sterilisation and vaccination before releasing the dogs.
But, on 7th November 2025, the Supreme Court further directed the removal of stray dogs from educational institutions, hospitals, sports complexes, bus stands, depots, and railway stations, mandating their relocation to designated shelters after their sterilisation and vaccination under the Animal Birth Control Rules, 2023.
However, from both a legal and practical standpoint, the ruling raises a significant challenge in animal welfare. Delhi stray dog population is estimated to be nearly one million, whereas existing shelters are not designed for long term confinement and are likely to become a hub for disease transmission, behavioural deterioration, overcrowding and violation of humane treatment of animals.
Animal Rights advocates argue that the ruling is inconsistent with India’s legal framework, The Prevention of Cruelty to Animal’s Act, 1960 and the Animal Birth Control Rules, 2023 which emphasise on sterilisation, vaccination, and return-to-location as the scientifically proven method of population management. Numerous empirical studies in India and abroad confirm that relocation disrupts territorial stability and often leads to the “vacuum effect” compelling unsterilised, unvaccinated dogs to move in to the place left behind by the earlier dogs and leading to an increase in public health risks.
The constitutional aspect adds another layer to the discussion. While Article 21 of the Constitution of India, 1950 guarantees the right to life and security, judicial decisions, particularly Animal Welfare Board of India vs A. Nagaraja & Ors (2014), recognise that animals have inherent dignity and the right to live without unnecessary suffering. Article 51A(g) also requires citizens to act with compassion toward all living things. This judicial view was further supported by the Punjab & Haryana High Court in Karnail Singh vs. State of Haryana (2009) where animals were given legal status, and citizens were seen as responsible for their well-being. Therefore, any policy that involves a mass relocation of animals must be evaluated on the basis of this constitutional commitment of humane treatment of animals.
International examples such as Thailand’s CNVR (Catch, Neuter, Vaccinate, Return) model and the humane programmes in Brazil and Bhutan show that long-term control of stray dog populations and related issues can be achieved through steady, evidence-based work rather than harsh or short-term measures. Indian cities like Jaipur, Lucknow and Dehradun have also shown strong results through consistent Animal Birth Control programmes supported by organisations like Humane World for Animals, India, proving that sterilisation, vaccination and regular monitoring make communities safer by using scientific technology.
Public awareness, safe interaction training, designated feeding places, behavioural checks for high-risk dogs and quick response in problem areas in a transparent manner can further reduce conflict without removing dogs from their territories. The 2025 directives have drawn much-needed attention to long-standing gaps in animal management policy. At the same time, they highlight the urgent need to bring public- health practices in line with legal and ethical responsibilities.
A framework guided by compassion and scientific principles will protect animals and will also help create safer and more stable cities. The intent is to not choose between human safety and animal rights, but to build a system where both can co-exist, while following constitutional values and global best practices.
By
Ms. Noyonika Gogoi
Assistant Professor of Law,
Asian Law College