Introduction

The Supreme Court’s order on August 11, 2025, mandating the relocation of all stray dogs in Delhi-NCR to shelters sparked significant public and legal discourse. Widely criticised as judicial overreach that disregarded statutory frameworks and urban realities, the order was soon modified. Within eleven days, the Court clarified that only rabid, suspected rabid, or aggressive dogs should be confined to shelters, while sterilised and vaccinated dogs were to be released back to their original locations. This revised directive, though emerging from controversy, has created an opportunity for a more balanced, lawful, and evidence-based approach to an issue that has troubled Indian cities for decades.

Legal and Institutional Framework

India’s legal provisions for animal welfare are well-established. The Prevention of Cruelty to Animals Act, 1960 lays the foundation for the humane treatment of animals. The Animal Birth Control (Dogs) Rules, originally notified in 2001 and updated in 2023, codify procedures for sterilising and vaccinating stray dogs, mandating their return to their native locations post-treatment. Judicial precedents from the Supreme Court and various High Courts have consistently upheld that stray dogs cannot be arbitrarily relocated or exterminated, affirming their constitutional right to life and dignity. In modifying its original order, the Supreme Court has attempted to realign with these legal principles, seeking to reconcile citizen safety with animal welfare.

The Collapse of the ABC Programme

Despite the soundness of the ABC framework in theory, its implementation has faltered across much of the country. Municipal bodies often lack basic infrastructure such as adequate shelters, trained dog catchers, qualified veterinarians, and vehicles. Fragmented coordination between civic authorities and NGOs, combined with irregular funding, has hampered consistent sterilisation efforts. As a result, the rules have largely failed to curtail urban dog populations. Recognising this failure, the Supreme Court has directed civic agencies to furnish data on their capacity and infrastructure—an essential step towards grounding policy decisions in empirical evidence and operational feasibility.

Reconciling Public Safety and Animal Rights

India’s estimated stray dog population ranges between 15 and 20 million, with annual dog bite incidents numbering around 1.5 to 2 million, according to official data from the NCRB and Ministry of Health and Family Welfare. Rabies remains a pressing public health concern, with the country accounting for 36% of global rabies deaths as per WHO estimates. However, animal rights advocates argue that indiscriminate removal or culling of dogs neither aligns with existing laws nor resolves the issue. The "vacuum effect"—where removed dogs are quickly replaced by new ones—makes such approaches ineffective. The Court’s revised position, allowing only truly aggressive or rabid dogs to be sheltered, thus appears to strike a middle ground that addresses human safety without violating legal and ethical mandates.

Urban Waste Management as a Crucial Factor

Stray dog populations are closely linked to the state of urban waste management. Open garbage dumps, meat markets, and uncollected food waste serve as primary food sources for street dogs. A 2016 report by the Central Pollution Control Board found that 70% of Indian cities do not practice waste segregation at source, effectively turning urban spaces into feeding grounds. Unless solid waste management systems are comprehensively reformed, sterilisation alone will be insufficient to reduce dog populations. The issue of stray dogs is therefore not just a matter of animal control but a symptom of larger urban governance challenges—particularly under the ambit of programmes like the Swachh Bharat Mission.

Civil Society and Community Involvement

Street-level engagement has emerged as a vital supplement to state efforts in managing stray dogs. Caregivers and feeders often ensure that dogs in their neighbourhoods are sterilised and vaccinated. Community-driven models—such as registering local dog feeders as caretakers—can help track vaccinations, identify behavioural changes, and monitor dog movements. Kerala’s successful community-led response to a rabies outbreak in 2017 stands as a model for such collaboration between citizens and public health authorities. These decentralised initiatives are crucial in bridging the capacity gap faced by municipalities.

Global Comparisons and Best Practices

International experiences provide important lessons. In Europe, countries like Germany and the Netherlands have achieved near-zero stray dog populations through rigorous pet ownership laws, mandatory microchipping, and strict breeding regulations. Sri Lanka has seen considerable reductions in rabies through mass canine vaccination campaigns. In parts of Latin America, sterilisation drives combined with regulated community feeding programmes have reduced aggression and bite incidents. While India cannot adopt these models wholesale due to different socio-economic contexts, adapting key components—like mass vaccination and community registration—can offer viable pathways to progress.

A Comprehensive Path Forward

·       The road to sustainable stray dog management lies in coordinated and multi-sectoral strategies. Strengthening the ABC Rules requires dedicated funding, greater collaboration with veterinary institutions and NGOs, and regular audits to ensure efficacy. Integrated urban waste management is equally critical. This includes strict enforcement of the Solid Waste Management Rules, 2016, mandatory source segregation, and the elimination of open garbage dumping sites. These efforts must be tied closely with national cleanliness initiatives like the Swachh Bharat Mission to ensure synergy across sectors.

·       Legal reforms are needed to clarify the jurisdictional roles between state and municipal authorities, with mechanisms for stronger accountability. Clearer guidelines on how to handle aggressive or rabid dogs—balancing both public safety and animal rights—will help standardise responses and reduce ad hoc decision-making.

·       Community engagement must be institutionalised through structured roles for local dog feeders and volunteers who can assist in vaccination tracking, behavioural observation, and awareness dissemination. Finally, there must be an investment in data systems: creating a national database of stray dog populations, using GIS mapping for sterilisation coverage and bite hotspots, and conducting periodic assessments through state animal welfare boards will offer the information backbone needed for long-term planning.

Conclusion

The Supreme Court’s stray dog directive, though initially flawed, has evolved into a legal and policy turning point. The issue at hand cannot be resolved merely by rounding up animals—it demands an integrated approach encompassing municipal reform, public health, waste management, legal clarity, and civil society partnership. By treating stray dog management not as an isolated challenge but as part of the broader urban ecosystem, India can craft a solution that is humane, lawful, and sustainable. The ultimate objective must be to ensure both public safety and animal welfare—without compromising on either.