Regulating India's Stray Animal Crisis: A Sustainable Model Of ABC, Public Health, And Shelter Reform
On 22 August 2025, a three-judge bench of the Supreme Court of India comprising Justice Vikram Nath, Justice Sandeep Mehta and Justice N V Anjaria, adopted a more balanced and humane approach while modifying an earlier order passed on 11 August, 2025, by a two-judge bench, in re: “City hounded by strays, kids pay price”. The previous order had directed that sterilised and vaccinated...
On 22 August 2025, a three-judge bench of the Supreme Court of India comprising Justice Vikram Nath, Justice Sandeep Mehta and Justice N V Anjaria, adopted a more balanced and humane approach while modifying an earlier order passed on 11 August, 2025, by a two-judge bench, in re: “City hounded by strays, kids pay price”. The previous order had directed that sterilised and vaccinated dogs should not be released back to public places. The Court found this order to be excessively harsh and inconsistent with the established ABC framework.
The Court emphasised that Rule 11(9) of the Animal Birth Control Rules, 2023, requires that sterilised, vaccinated dogs must be returned to the same locality from which they were captured. The Court identified two objectives behind this requirement. First, it prevents overcrowding in shelters, which already suffer from severe infrastructural limitations. Second, it ensures that sterilised and vaccinated dogs are returned to the environment familiar to them, a measure that is both practical and compassionate.
This model is known as the Capture Neuter Vaccinate Release or CNVR model, which has been endorsed and recognised by organisations like the World Organisation for Animal Health, the World Health Organisation, and the World Society for the Protection of Animals. It is regarded as the most humane and scientifically effective method for controlling stray dog populations across urban environments. The success of the CNVR model comes from its scientifically integrated approach on population control, public health, and animal behaviour. We know how sterilisation and vaccination are beneficial for stray dogs and public health. With releasing sterilised dogs back to their communities, the model sustains territorial stability, which is crucial because removal seldom creates a vacuum effect. This vacuum allows the unsterilised dogs from neighbouring areas to migrate and settle in the vacant space, countering the earlier efforts. By keeping sterilised territorial dogs, the CNVR model makes sure the stability and prevents uncontrolled influxes.
The validity of the model is further strengthened by behavioural benefits of sterilisation. Sterilised dogs become less aggressive, with low mating related conflicts, and less roaming habits. These behavioural changes would reduce the dog bite incidents, thereby addressing an important public health issue. A study published in the Indian Veterinary Journal, observed that the CNVR model interventions significantly lowered nuisance behaviours and reduced bite incidents.
Elena Garde in her article published in the Preventive Veterinary Medicine, found that the result of sterilisation would not directly reduce aggression in dogs, but significantly curtailed roaming and mating behaviours that indirectly lead to conflict. National Institutes of Health Reviews highlight reduced aggression as a outcome of sterilisation, making dogs more calm and less likely to attack. These findings wholly provide a strong scientific base for the CNVR Model.
Constitutional and Statutory background
Article 51A(g) of the Indian Constitution imposes duty on every citizen to have compassion toward all living creatures. In accordance with this constitutional principle, the Central Government introduced the Animal Birth Control Rules, 2023, under the Prevention of Cruelty to Animals Act, 1960. The 2023 Rules impose implementation duties on local bodies. It further provides a mandatory certification of animal welfare organisations by the Animal Welfare Board of India, maintenance of systematic records, establishment of adequate veterinary infrastructure such as kennels and surgical vans, and mechanisms for transparent monitoring. On 16th of July 2025, the Central Government gave directions to all the states to create ABC units and guarantee at least 70% of stray dogs to get cover under the drive.
The ground-level realities, however, reflect issues such as insufficient facilities, poor record-keeping, and a lack of expertise with non-cooperation between local authorities and welfare organisations.
Importance of Shelter Infrastructure
The shelter infrastructure lays the foundation stone of a successful ABC programme. Shelters provide spaces where captured dogs can be sterilised, vaccinated, and monitored during recovery. Without well-equipped shelters, the CNVR model cannot function effectively.
The order of 11 August 2025, which prohibited the release of sterilised dogs, was criticised nationwide for being impractical and morally questionable. India does not have adequate shelter facilities to indefinitely house sterilised dogs. The three judge bench that modified this order rightly observed that such a mandate would require “logistics of gargantuan proportions” including shelters, veterinarians, cages, and specialised vehicles. In the absence of these resources, it may lead to a catch-22 situation making the order impossible to implement.
Many media reports have revealed that inadequate shelters have led to increased animal mortality, unsanitary conditions, and poor post-operative care. These failures compromise animal welfare, reduce the efficiency of ABC programmes, and erode public trust.
Toward a Sustainable Model of ABC: Challenges and Solutions
To create an animal-friendly environment in urban and rural areas, India requires a comprehensive ABC model that extends beyond the sterilisation of community animal alone. For example, stray cattle are the major challenge in urban and semi-urban areas. They create traffic issues, damage property and crops, and endure agony from inadequate care. ABC programmes are not applicable on cattle, however, their management is equally essential.
Articles 246(3) and 243(W) of the Indian Constitution situate livestock management under the jurisdiction of State Governments and the management of cattle pounds and shelters under the jurisdiction of local bodies, respectively. Many States have established gaushalas for stray cattle. Rashtriya Gokul Mission, an initiative taken by the Central Government, promotes sex-sorted semen technology that helps in reducing the unwanted birth of male calves. Nevertheless, ground realities remain disturbing. Corruption and mismanagement in gaushalas result in the death of cattle due to shortage of food, care, and medical treatment despite large budgetary allocations. The absence of transparency and accountability jeopardises the basic objectives of shelters and weakens public confidence.
Another matter of concern is commercial dog breeding. The Dog Breeding and Marketing Rules of 2017, lay down standards requiring registration with State Animal Welfare Boards. It prohibits inbreeding and overbreeding, and inhumane treatment of puppies. Weak enforcement however, enabled illicit breeding practices to be continued unabated. Unlicensed breeders still illicitly operate, creating conditions similar to puppy mills.
Abandonment of pets aggravates this issue. Section 11(i) of the Prevention of Cruelty to Animals Act, 1960 makes practice of animal abandonment, a criminal offence, but a minimal token fine imposed is inadequate to act as a deterrent. A culture of passionate pet buying for fashion with absence of awareness about responsibilities, leading to a lack of emotional attachment with pets, has led to rising abandonment.
Community involvement is central to sustainable animal welfare. Public education campaigns should focus on responsible pet ownership, benefits of sterilisation, and humane treatment of animals. Since attitudes toward animals vary across communities, campaigns must be sensitive.
Rabies prevention is a critical component of community health. Although the disease is 100 % fatal once symptoms appear, it is entirely preventable through timely prophylaxis. Recently in Kerala, two incidents reported of rabies deaths, despite vaccination, have exposed the risk of poor adherence to protocols. Authorities underlined that rabies post-exposure prophylaxis is only effective when wound washing, correct vaccine administration, and timely rabies immunoglobulin use are ensured, particularly in children.
India plans to eliminate rabies by 2030 through its National Action Plan for Dog Mediated Rabies Elimination. It aligns with the global Zero by 30 strategy. It aims mass level dog vaccination and universal availability of prophylaxis. To achieve these goals, it requires not only medical infrastructure but also consistent community engagement and cooperation with inter departmental bodies. ABC programmes must also explore innovative reproductive technologies such as hormonal implants, immune contraceptive vaccines, and non-surgical fertility control. They can be beneficial, when surgery is life-threatening. These technologies are helpful in cases where capturing and handling pose risks. Shelter infrastructure must evolve to accommodate diverse needs for effective multispecies interventions. Facilities should include veterinary staff trained in multispecies care, specialised equipment, and regional networks capable of sharing expertise. This integrated system would enhance efficiency in general.
Therefore, Sustainable Animal Birth Control with multi-species initiatives, infrastructural development, and overall strategies would need a significant amount of financial funding. Innovative financing models such as public-private partnership (PPP), community-based financing, and global partnership can be used to bridge these gaps.
Monitoring and evaluation systems are equally important. There must be indicators to measure animal welfare outcomes, public health improvements, and community satisfaction. A comprehensive management, with continuous data collection and analysis, makes sure that interventions remain effective.
The management of community animals in India requires an integrated model, which must be scientifically proven and socially accepted. The CNVR model provides an efficient foundation but its success depends on the infrastructural development, innovative use of technology, regulation of responsible breeding, and active community participation.
India can transform its urban and rural areas into an environment where humans and animals could peacefully coexist harmoniously. India can be a model for the other developing nations facing similar issues and can also demonstrate that governance, science, and compassion could work hand in hand to provide sustainable animal welfare solutions.
The author is an Advocate practicing in Lucknow District Court. Views are personal.