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Failure to Protect Citizens from Dog Bites Violates Article 21: Supreme Court Issues Sweeping Nationwide Directions on Stray Dog and Cattle Menace in Public and Institutional Spaces

08 November 2025 9:18 AM

By: Admin


“The menace of stray dog attacks in institutional areas is not merely a public-health challenge, but a constitutional failure — a breach of the fundamental right to life under Article 21” - In a powerful and far-reaching judgment delivered on 7 November 2025, the Supreme Court of India laid down comprehensive, time-bound, and enforceable guidelines to combat the escalating threat posed by stray animals, especially dog-bite incidents in schools, hospitals, stadia, transport hubs and highways across the country. The Court unequivocally held that “exposure to preventable injury and disease from stray animal attacks in public and institutional spaces is a direct violation of the right to life under Article 21 of the Constitution.”

A three-judge Bench comprising Justice Vikram Nath, Justice Sandeep Mehta, and Justice N.V. Anjaria directed States, Union Territories, the Union of India, and various public bodies to implement systematic safety measures, enforce the Animal Birth Control (Dogs) Rules, 2023, and ensure institutional and infrastructural security in both urban and rural public spaces.

The judgment was passed in a batch of suo motu and tagged matters including Suo Motu Writ Petition (C) No. 5 of 2025, and several Special Leave Petitions and Transfer Petitions concerning incidents of stray animal attacks across India.

“We Cannot Permit Public Premises to Become Unsafe Due to Stray Animal Attacks”

Court Calls Dog Bite Incidents in Schools, Hospitals and Bus Terminals a Constitutional Emergency

The Supreme Court’s ruling was prompted by alarming data and detailed incident reports from across India revealing a disturbing rise in dog bite incidents inside classrooms, hospital corridors, stadiums, railway stations, and bus stands, with victims ranging from school children and elderly patients to foreign visitors and public officials.

The Court stated:
“The recurrence of such incidents, particularly within institutional spaces meant for learning, healing, and recreation, reflects not only administrative apathy but also a systemic failure to secure these premises from preventable hazards.”

Referring to Article 21 of the Constitution, the Court held:
“Exposure to unprovoked stray animal attacks, particularly on children, patients, and commuters in public spaces, infringes upon their right to life, dignity, and safe environments. This is not just a matter of public health — it is a constitutional issue.”

“Stray Dogs Shall Not Be Released Back Into Institutional Areas After Sterilisation”

Supreme Court Clarifies: Public Health Must Take Priority Within Educational, Medical, and Transit Premises

In a clear departure from the standard “capture-sterilise-vaccinate-release” (CSVR) framework under the ABC Rules, the Court directed that dogs captured from institutional premises shall not be released back to the same location, stating:
“We have consciously directed the non-release of such stray dogs to the same location from which they were picked up, as permitting the same would frustrate the very effect of the directions issued to liberate such institutional areas from the presence of stray dogs.”

The Court made it clear that public institutions are entitled to be free from stray dog presence, especially where children, patients, or athletes are present.
It further emphasized that schools and hospitals are not dog shelters, and public safety must override release-based protocols, so long as sterilisation and care are provided at designated shelters.

“The Constitution Guarantees Safe Roads, Not Ones Obstructed by Cattle and Stray Animals”

Directions of Rajasthan High Court Extended Nationwide to Remove Stray Cattle From Highways

Acknowledging the rising fatalities and injuries from cattle and stray animal-related road accidents, especially at night and in high-speed zones, the Court extended the directions of the Rajasthan High Court (Jodhpur) in D.B. Civil Writ Petition No. 14726 of 2025 to the entire nation.

The Court observed:
“Accidents caused by cattle and other stray animals on public roads and highways have become alarmingly frequent... such incidents are symptomatic of a larger failure on the part of the administrative authorities entrusted with public safety.”

It held that such neglect undermines the right to safe mobility, also protected under Article 21, and directed all States, UTs, PWDs, and NHAI to immediately initiate:

  • Removal and sheltering of stray cattle from highways
  • Constitution of highway patrol units
  • Deployment of 24x7 surveillance teams
  • Installation of signage and helpline numbers at regular intervals
  • Accountability of district and field officers in case of further incidents

The Court mandated that status-cum-compliance affidavits be filed within 8 weeks, warning that “any administrative indifference will be viewed as contempt.

“Dog Bites Have Breached the Threshold of a Public Health Crisis: Administrative Inertia Is Not an Option”

Court Reviews Disturbing Incidents from Across the Country in Educational and Health Institutions

In a detailed factual analysis, the Court chronicled disturbing dog bite incidents from multiple States, including:

  • Wayanad, Kerala – A Class III child bitten inside the classroom where the dog had given birth near the school wash basin
  • Hisar, Haryana – Six students bitten inside a government primary school
  • Bengaluru – University students attacked by strays on campus
  • Nagpur and Chennai Hospitals – Doctors and patients severely bitten, including one resident doctor requiring ICU care
  • Jawaharlal Nehru Stadium, New Delhi – Two foreign coaches bitten during World Para Athletics Championship
  • Kannur and Alappuzha Railway Stations – Dozens of people bitten by rabid dogs
  • KSRTC Bus Stand, Kottayam – Over 50 people attacked by a single stray dog

These accounts, the Court said, “highlight a systemic failure across municipalities and institutional administrations. Premises which should be the safest — schools, hospitals, and transport hubs — have become sites of recurring trauma.”

“No Citizen Should Be Exposed to Preventable Injury on Public Premises”

Sweeping Directions Issued for Fencing, Surveillance, Vaccination and Coordination in All Institutional Spaces

Recognising the institutional nature of the failure, the Court issued an exhaustive set of binding directions applicable across the country:

  • All educational institutions, hospitals, stadia, bus depots and railway stations, public or private, must be identified within two weeks.
  • Perimeter security including fencing, gates and structural barriers to prevent ingress of stray dogs must be implemented within 8 weeks.
  • Every institution must appoint a Nodal Officer to maintain cleanliness, ensure dog-free zones, and coordinate with municipal authorities.
  • Stray dogs found within these premises shall be removed and sheltered, but not released back to the same location, even if sterilised.
  • Municipal authorities must carry out quarterly inspections of such spaces, and any lapse shall invite personal accountability.
  • All hospitals are directed to stock anti-rabies vaccine and immunoglobulin at all times.
  • Awareness sessions in schools regarding dog-bite prevention and first-aid are now mandatory.
  • The Animal Welfare Board of India must issue a national SOP for stray dog management within institutional spaces within 4 weeks.

The Court emphasized that “the objective is not to vilify stray animals, but to assert the fundamental right of citizens to safe public spaces, without fear of preventable harm.”

“Public Health Policy Must Be Humane, But Also Accountable”

Implementation of Animal Birth Control (Dogs) Rules, 2023 Must Be Strengthened, Not Diluted

While reaffirming the humane intent behind the Animal Birth Control (Dogs) Rules, 2023, the Court noted that failure to implement these rules effectively has allowed the problem to worsen.

It stated:
“Despite the statutory framework of the ABC Rules and various municipal bye-laws, the practical outcomes remain suboptimal. The problem calls for a holistic and coordinated approach involving municipalities, health departments, and institutional administrations.”

The Court called for better coordination between municipal bodies and institutional managers, and insisted on robust waste disposal systems, since poor garbage practices were contributing to stray dog congregation.

“Next Hearing Fixed for January 2026: Non-Compliance Will Invite Contempt”

The Court directed all Chief Secretaries, Central Ministries, and the Animal Welfare Board of India to file comprehensive compliance affidavits within 8 weeks, outlining:

  • Measures taken to secure institutional premises
  • Coordination mechanisms with municipal and Panchayati Raj bodies
  • Availability of vaccines and public health preparedness
  • Status of sterilisation drives and implementation of new SOPs

The Court concluded with a stern warning:
“Any reported non-compliance shall be viewed very seriously and may invite penalties including initiation of suo motu contempt proceedings.”

The matter is now posted for further directions on 13 January 2026.

Date of Decision: 7 November 2025

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