The Supreme Court on Tuesday May 19 dismissed all challenges on stray dog management and warned that the state cannot remain a “passive spectator” as citizens face the constant threat of dog attacks in public spaces.

The bench comprising Justices Vikram Nath, Sandeep Mehta and N V Anjaria, while delivering the judgment, said the country’s stray dog crisis had reached alarming proportions because of years of poor implementation of the ABC framework.

The court said the framework introduced in 2001 had suffered from a “discernible absence of efforts” to build infrastructure that supports the growing stray dog population. Sterilisation and vaccination drives remained sporadic and lacked “institutional depth”.

Linking the issue directly to Article 21 of the Constitution, the court held that the right to life includes the right to move freely in public spaces without fear of attack. “The Constitution does not envisage a society where children and elderly citizens are left to survive on the mercy of physical strength or chance”.

Warning authorities against continued inaction, the court said any failure to comply with its directions and the AWBI framework could invite contempt proceedings and disciplinary action.

What had triggered the case?

The SC stepped into the stray dogs issue last July after taking suo motu cognizance of a news report about a 6-year-old girl in New Delhi who died after a dog bite and suspected rabies infection. Calling the incidents and the rise of dog attacks and rabies deaths “disturbing”, the court said the stray dog issue had become a serious public safety concern.

The case first came before a bench of Justices JB Paridwala and R Mahadevan, who in August 2025 directed civic authorities across Delhi-NCR to pick up stray dogs from public places and move them to shelters. It also said the dogs should not be released back onto the streets, observing that people should be able to move around freely without the fear of being attacked.

The order immediately triggered protests from animal welfare groups and dog feeders who argued that the directions were contrary to the Animal Birth Control Rules 2023. The rules require stray dogs to be sterilised and vaccinated before being released back into the same area from where they were picked up.

Applications were filed in the SC seeking to have this order recalled. The matter was eventually placed before a larger 3-judge bench led by Justice Vikram Nath. The court eventually softened the earlier directions and restored the existing sterilisation and release policy under the ABC rules while allowing authorities to keep rabid or aggressive dogs in shelters. It also barred the feeding of stray dogs in public spaces outside designated feeding zones.

Previous hearings

Resident groups and families of dog bite victims argued that authorities had failed to control rising attacks, especially near schools, hospitals, residential colonies, etc. They told the court that the issue could no longer be treated only as an animal welfare concern when children and elderly people were repeatedly being attacked.

Animal welfare groups took the opposite view, arguing that mass removal of dogs was neither sustainable nor effective. As dogs are territorial animals, removing sterilised dogs from an area would only create space for unsterilised dogs to move in, which would eventually worsen the problem over time.

Gradually, the hearings broadened into a review of how municipal bodies and states were implementing sterilisation, shelter and vaccination policies.

In November 2025, the court passed another interim order directing states and the National Highway Authority of India to remove stray animals from highways and institutional premises such as schools and hospitals. It also directed the fencing of such premises.

What the Supreme Court directed

The court on Tuesday directed every district in the country to establish at least one fully functional ABC centre and asked States and Union Territories to expand infrastructure depending on population density and local requirements.

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It also ordered authorities to ensure adequate availability of anti-rabies medicines and improve veterinary and vaccination services.

The Bench also directed the NHAI and States to create a coordinated mechanism for dealing with stray animals on highways and expressways, including transport vehicles, shelter facilities and coordination with animal welfare organisations.

The court further held that authorities may take legally permissible measures, including euthanasia, in cases involving rabid, incurably ill or demonstrably dangerous and aggressive dogs posing a threat to human life, strictly in accordance with the Prevention of Cruelty to Animals Act and the ABC Rules. The court also directed all High Courts to register suo motu continuing proceedings to monitor the implementation of its directions.

The Animal Birth Control Rules, 2023, issued under the Prevention of Cruelty to Animals Act, 1960, treat sterilisation and anti-rabies vaccination as the primary way to control stray dog populations. They also require dogs to be released back into the same locality after sterilisation, recognising that stray dogs are territorial by nature.

The Rules do not permit indiscriminate killing or relocation of dogs. Euthanasia is allowed only in limited situations involving rabid, terminally ill or fatally injured animals.

The case also raised constitutional concerns. Animal welfare groups relied on Article 51A(g), which asks citizens to show compassion towards living creatures. Petitioners representing residents and bite victims argued that unchecked stray dog populations affected citizens’ rights under Articles 19 and 21, including the right to move freely and live safely.