Supreme Court’s New Rule: Stray Dogs Can Be Returned to Streets After Sterilization

This Supreme Court order modifies its earlier directions on stray dog management, balancing fundamental rights under Article 21 (Right to Life) with the statutory Animal Birth Control (ABC) Rules, 2023. The Court clarified that sterilized and immunized dogs must be released back to their localities as per Rule 11(19) of the ABC Rules, while allowing permanent impounding only for rabid or aggressively dangerous dogs. It issued supplementary directives, including creating designated feeding zones, and expanded the case’s scope to all states and union territories for a uniform national policy.

Facts Of The Case:

The Supreme Court’s intervention was triggered by a suo motu cognizance of a news report titled “City Hounded by Strays, Kids Pay Price,” detailing the death of a six-year-old girl from rabies after a dog attack in Delhi, alleging official apathy. This case was clubbed with other pending petitions, including challenges to High Court orders concerning the implementation of the Animal Birth Control (ABC) Rules, 2023, and a petition from a resident facing harassment while feeding community dogs. Initially, on August 11, 2025, a two-judge bench issued stringent directives, ordering municipal authorities in the National Capital Region (NCR) to immediately round up all stray dogs, place them in shelters, and crucially, not release them back onto the streets after sterilization and immunization. This directive was challenged by animal rights organizations and individuals (“animal lovers”) who argued it violated the specific mandate of Rule 11(19) of the ABC Rules, which requires the release of treated dogs to their original locations. They also raised concerns about the logistical impossibility of housing lakhs of dogs permanently and the potential for culling. The Solicitor General, representing the government, emphasized the severe public health crisis, citing thousands of dog bite incidents and the threat to citizens’ Right to Life under Article 21. The three-judge bench was thus tasked with balancing these competing interests—public safety from stray dog attacks and rabies against the statutory framework and animal welfare.

Procedural History:

The Supreme Court initiated the case by taking suo motu cognizance on July 28, 2025, based on a news report about a fatal dog attack. This was registered as Suo Motu Writ Petition (Civil) No. 5 of 2025. On August 11, 2025, a two-judge bench of the Court heard the matter and issued sweeping mandatory directions for the rounding up and permanent impounding of stray dogs across the National Capital Region (NCR). Subsequently, numerous intervention applications were filed by individuals and NGOs challenging these directions. Following this, the Hon’ble Chief Justice of India clubbed this suo motu petition with two other pending Special Leave Petitions and a new writ petition, all concerning similar issues of stray dog management and the ABC Rules. The consolidated matters were then placed before a three-judge bench for a comprehensive hearing, which culminated in the modifying order of August 22, 2025, that forms the present judgement.

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Court Observation:

In its observations, the Court acknowledged the salutary intent behind the original order to protect citizens’ Right to Life under Article 21 from the threat of rabid and aggressive stray dogs. However, the Bench found that the blanket prohibition on releasing sterilized and immunized dogs was overly harsh and operated outside the statutory framework of the Animal Birth Control (ABC) Rules, 2023. The Court emphasized that Rule 11(19) of the ABC Rules, which mandates the release of treated dogs to their original localities, is a scientifically and compassionately carved provision that also prevents shelter overcrowding. It observed that while aggressive sterilization is key to population control, a holistic and balanced approach was necessary, as the initial directions were logistically impractical and failed to consider the existing infrastructure limitations of municipal authorities. The Court thus prioritized a harmonious interpretation that respects the legal mandate while addressing public safety concerns.

Final Decision & Judgement:

The Supreme Court, in its final decision, modified the earlier stringent directives. It ruled that sterilized, vaccinated, and healthy stray dogs must be released back to their original localities as mandated by the Animal Birth Control (ABC) Rules, 2023. However, dogs confirmed or suspected to be rabid, or those displaying aggressive behaviour, are to be permanently impounded and not released. The Court supplemented its judgement with new directives, including the creation of designated dog feeding zones in every municipal ward, a ban on street feeding elsewhere, and the imposition of costs on intervening NGOs and individuals to fund infrastructure. It also expanded the case’s scope to all States and Union Territories to develop a uniform national policy, transferring all similar pending cases from various High Courts to itself for consolidated adjudication.

Case Details:

Case Title: In Re: “City Hounded by Strays, Kids Pay Price” 
CITATION: 2025 INSC 1018
Writ Petition : (Civil) No. 784 of 2025
Date of Judgement: August 22, 2025
Judges/Justice Name:  Justice Vikram Nath &  Justice Sandeep Mehta, and Justice N. V. Anjaria
Download The Judgement Here

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