Bench proceedings and orders — Stray dogs in Delhi-NCR
A Bench of Two Hon’ble Judges of the Supreme Court comprising Hon’ble Justice J. B. Pardiwala & Mr Justice R Mahadevan, took Suo Moto cognizance on 28th July, 2025, of a news report published in The Times of India, Delhi Edition, titled “City Hounded by Strays, Kids Pay.”
Pursuant to the taking of suo moto cognizance, the matter came to be listed before the Bench on 11th August 2025, on which the following directions were issued:
“12. For the present, the aforesaid directions shall be complied with and implemented scrupulously. We, at the cost of repetition, again make it abundantly clear to the above concerned authorities in clear words that it shall at the earliest:
- Start picking up and rounding the stray dogs from all localities of Delhi, Ghaziabad, NOIDA, Faridabad, Gurugram as well as areas on the outskirts, and relocate these dogs into designated shelters/pounds.
- The appropriate authorities of NCT of Delhi, NOIDA, Ghaziabad, Gurugram & Faridabad are directed to immediately create dog shelters/pounds and report to this Court the creation of such infrastructure all over the National Capital Region (NCR). A report in this regard shall be filed before this Court within a period of eight-weeks.
- In no circumstances, should these stray dogs after their relocation be once again released back onto the streets. In this regard proper records should be maintained by the concerned authorities regularly.
- The stray dogs shall be captured, sterilized, dewormed and immunized as required by Animal Birth Control Rules, 2023 and as noted above, shall not be released back. The dog shelters/pounds should have sufficient personnel to sterilize, deworm and immunize stray dogs and also for looking after the stray dogs who would be detained.
- We further make it clear that both the exercise of rounding up of stray dogs as well as the creation of necessary infrastructure in the form of shelters/pounds for the relocation, sterilization, deworming and immunization, shall be undertaken simultaneously. We do not want to hear about even a semblance of lethargy from the concerned authorities on the pre-text of awaiting the creation of shelters/pounds, otherwise, we will proceed to take strict action against these authorities. All authorities are directed to immediately begin the picking up stray dogs and in the same breadth creation of appropriate and adequate shelter homes and pounds across the National Capital Region.
13. Any hindrance or obstruction that may be caused by any individual or organization in the smooth and effective implementation of our aforesaid directions will be viewed as contempt of this Court and we shall proceed to take appropriate action in accordance with law.”
In the intervening period, several interlocutory applications for intervention came to be filed purportedly by individuals and organizations working for the welfare of the stray dogs, seeking a stay on the directions contained in the order dated 11th August, 2025.
Background statistics and public safety concerns
India accounts for a significant portion of global rabies deaths, specifically 36%, according to the World Health Organization (WHO). Additionally, India contributes to 65% of rabies deaths within the South East Asia region. Dog bites are the primary cause, responsible for approximately 96% of rabies-related deaths in India. India reported over 37 lakh (3.7 million) dog bite cases in 2024, according to the government in July 2025, with a total of 37,17,336 cases recorded. These figures show a substantial increase from the 21.9 lakh cases in 2022 and reflect an ongoing trend of fluctuating numbers in the years following the pandemic.
Every locality in our cities and towns is virtually under siege by packs of dogs whose ferocity and aggressiveness during night hours cause serious concerns. They virulently chase and attack competing pack members, other animals, people travelling on cycles, scooters, motor-cycles and vehicles – in short – any moving object. Horrendous instances are regularly reported of stray dogs mauling children, wounding adults or going on biting sprees. Many Urban Local bodies are initiating a garbage collection system through mobile vans; the resultant non-availability of food for street dogs, making them more ferocious and aggressive.
Dog bites causes immense pain and suffering to humans, especially to children, elderly and disabled persons. One has to thereafter undergo a very rigorous and timely process of taking multiple injections. If a person is not aware of the medical treatment or if the injections are not genuine, it would result in a very painful death. Sometimes, the person may not get necessary treatment in timely manner. The disease becomes incurable after 24 hours and results in a certain death. In a number of cases, stray dogs have attacked children, elderly persons and even adults, which have resulted in painful death to the victims at the spot [or soon thereafter].
Stray dogs are also a cause of large number of road accidents, which cause injuries/ deaths of road users. Even if a person may not die of a dog bite, due to evasive action taken by him, he may fall down or hit another vehicle, resulting in death/injury.
The “streeties”, the “Indies”, the ones who are fed leftovers on the street, the ones who “enjoy” a free life, coming and going as they choose, forming alliances and barking through the night, to ward off intruding packs. These dogs bark and chase any passer-by, be they morning joggers or someone returning home late at night.
Legal framework
The Government of India’s response to remedy this infringement of our Fundamental Rights is manifested in Animal Birth Control (Dog) Rules 2001, and recently [after repeal of the 2001 Rules] in the Animal Birth Control Rules, 2023 [2023 Rules]. The said Rules have been framed in exercise of powers under Section 38 (1) & (2) of Prevention of Cruelty to Animals Act, 1960. The Rule 11 broadly provide that the local authority would provide for manpower and infrastructure for capturing of stray dogs, sterilization and immunization and thereafter releasing the dogs at the very same place from where they were captured.
Issues before the Court
The issue involved in the petitions placed before the Three-Judge Bench which centred around the right of the stray dogs to live on the streets, vis-à-vis, the safety and security of the citizens particularly the kids and elderly people from these very stray dogs, many of whom are suspected to be infected with the communicable disease, i.e., rabies. It is indisputable that human beings bitten by rabid dogs suffer indescribably, and many times, the infection proves to be fatal.
Per contra, Shri Tushar Mehta, learned Solicitor General of India, appearing for the GNCTD urged that reports estimate that approximately 37,15,713 dog bites occurred in India in 2024, and in several cases, human lives were lost due to trauma and rabies infection. The reports mention that the presence of aggressive stray dogs on streets is causing grave risk to the lives of children and elderly people, as well as other vulnerable sections of society. They are unable to access streets and parks because of the fear of being attacked and bitten by the rabies-infected stray dogs.
Feeding and territoriality
Feeding stray dogs is making them territorial, which leads them to attack people who enter “their territory” and adding to menace. The Supreme Court held that it is illegal to feed stray dogs on the streets and in public places. The Supreme Court directed that stray dogs must be fed only in the dedicated feeding spaces to be created in each Municipal Ward by the authorities;
“Municipal authorities shall forthwith commence an exercise for creating dedicated feeding spaces for the stray dogs in each municipal ward. The feeding areas shall be created/identified keeping in view the population and concentration of stray dogs in the particular municipal ward. Gantries/notice boards shall be placed near such designated feeding areas, mentioning that stray dogs shall only be fed in such areas. Under no condition shall the feeding of stray dogs on the streets be permitted. The persons found feeding the dogs on the streets in contravention of the above directions shall be liable to be proceeded against under the relevant legal framework.”
The Supreme Court passed direction on the basis of reports regarding untoward incidents caused by the unregulated feeding of stray dogs. The Supreme stated that this practice must be eliminated so that the common citizens walking on the streets are not put to difficulties.
A Bench of Justice Vikram Nath, Justice Sandeep Mehta & Justice N. V. Anjaria passed this direction while modifying the August 11, 2025 Order passed by a Two-Judge Bench which directed the relocation of the stray dogs in Delhi-NCR to dog shelters.
Each municipal authority shall create a dedicated helpline number for reporting incidents of violation of the above directions. On such a report being received, appropriate measures shall be taken against the individuals/NGOs concerned.
The Three-Judge Bench clarified that the dogs, which are picked up, must be released to the same place from which they were picked up, after vaccination and sterilization, except those which are infected with rabies, suspected to the infected with rabies or displaying aggressive behaviour.
The Supreme Court reiterated the direction given in Para 13 of the Order dated 11th August 2025, with slight modification that no individual or organization shall cause any hindrance or obstruction in the effective implementation of the directions given above. In case any public servant acting in compliance with the aforesaid directions is obstructed, then the violator/s shall be liable to face prosecution for obstructing the public servant acting in discharge of official duty. The Supreme Court further ordered the prohibition on public feeding.
Written By: Dinesh Singh Chauhan, Advocate High Court of J&K And LadakhEmail: [email protected], [email protected]